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TDNetworkPro — Dealer Platform User Agreement & Compliance Policy

TDNetworkPro operates as a cooperative credit information exchange platform among mobile tool dealers. By creating an account, you acknowledge that this platform may constitute a consumer reporting system subject to the Fair Credit Reporting Act (FCRA), 15 U.S.C. § 1681 et seq., applicable antitrust laws, and related federal and state regulations. You agree to the following terms in their entirety.

1. Permissible Purpose — Required Declaration

You certify that you will access customer information on this platform solely for legitimate credit evaluation purposes in connection with a credit transaction involving the specific individual — specifically, to unilaterally evaluate whether to extend trade credit, payment plans, or tool financing to that consumer. This is the sole permissible purpose under FCRA § 604(a)(3)(A). You will not access records for any other purpose, including but not limited to marketing, sales prospecting, competitive intelligence, to reach agreement with any other TDNetworkPro user, or any non-credit purpose.

2. Accuracy & Furnisher Obligations (FCRA § 623)

• You will only submit information that is accurate, complete, and verifiable to the best of your knowledge at the time of entry.
• If you discover that information you submitted is inaccurate or incomplete, you must promptly correct or delete it — continuing to furnish known inaccurate data is a direct FCRA violation.
• Entries must include only factual, objective credit-related data: balance owed, last invoice number, date of last payment, customer status, and payment score. No opinions, characterizations, or subjective assessments.
• You must not report information that is the result of identity theft once you have been notified of that fact.

3. Seven-Year Reporting Limit (FCRA § 605)

Adverse information submitted to this platform should not reference events or delinquencies that are more than seven (7) years old. Reporting outdated adverse items beyond this period is prohibited under FCRA § 605(a).

4. Consumer Dispute Rights

If a consumer contacts you to dispute the accuracy or completeness of an entry you submitted, you are obligated under FCRA § 623 to conduct a reasonable investigation and correct or delete any information found to be inaccurate or unverifiable. You agree to cooperate with TDNetworkPro in processing any consumer disputes related to your entries.

5. Adverse Action Notice Requirement

If you deny credit, reduce credit limits, or take other adverse action against a consumer based in whole or in part on information obtained from this platform, you may be required under FCRA § 615 to provide that consumer with an adverse action notice identifying TDNetworkPro as a source of information used in the decision. You are solely responsible for compliance with applicable adverse action notification requirements.

6. Antitrust Compliance — Prohibited Topics

Because dealers on this platform are competitors, all communications are subject to strict antitrust guidelines. The following are strictly prohibited in all entries, messages, and platform interactions:

• Prices — current, future, prospective, or any factors determinative of pricing
• Credit terms or payment terms of any kind (net 30, discounts, late charges, whether terms are negotiable)
• Future actions, plans, policies, or intentions regarding a customer or account
• Opinions, rumors, advice, or strategy about customers
• Agreements or implied coordination on extending or refusing credit, boycotts, or blacklisting
• Market or territory allocation, customer allocation, or dividing markets
• Profit margins, costs, production plans, sales discounts, or other competitively sensitive business information
• Bids, intent to bid or not bid, or anything related to bidding practices
• Any arrangement that interferes with independent business judgment on credit or sales decisions

7. Confidentiality & Data Use Restrictions

• All information accessed on this platform is confidential and strictly for your individual credit evaluation use only.
• You will not share platform data with sales, marketing, or non-credit personnel within your organization.
• You will not disclose any information obtained from this platform to the consumer who is the subject of that information, or to any third party not involved in the credit decision.
• You will not use platform data for marketing, advertising, competitive intelligence, or any purpose other than individual credit evaluation.

8. Dealer Messaging Restrictions

• Dealer-to-dealer messages are tied to specific customer records only and may not be used for general business discussions.
• Messages may only be initiated from a customer record and must relate directly to that customer's credit history.
• No continuing discussions outside the platform about information shared through platform messages.

9. Platform Classification Notice

TDNetworkPro may be considered a Consumer Reporting Agency (CRA) or a cooperative credit exchange subject to FCRA regulations. You acknowledge that as a user and furnisher of information on this platform, you have independent legal obligations under FCRA and applicable antitrust law, regardless of TDNetworkPro's own compliance status. You are solely responsible for ensuring your use of this platform complies with all applicable federal and state laws.

10. Enforcement & Account Termination

TDNetworkPro reserves the right to suspend or permanently terminate any account found to be in violation of these terms. Violations of FCRA or antitrust law may result in civil liability, regulatory enforcement action, and criminal penalties. Willful violation of FCRA § 620 may result in criminal prosecution.

This agreement does not constitute legal advice. You are encouraged to consult with legal counsel regarding your specific obligations under FCRA and applicable antitrust law.