Underwritetenant/underwrite-demo
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Operator surfaces: queues, clocks, correspondence, billing.

Compliance infrastructure

The statute, compiled into the case record.

A white label dispute platform for credit repair operators. Disclosures, clocks and cancellation windows are controls, not reminders.

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CR-2026-04187Investigation openopened 2026-07-14

Parties

Operator
Northgate Credit Services tenant/northgate
Consumer
Consumer #A-4187
Reporting agency
CRA-02
Furnisher
FUR-118
Item
Tradeline 4417, reported balance and date of last activity
Basis
Accuracy and completeness of the reported date of last activity
Statutory clock

FCRA 611(a)(1)(A)

30 days

Started
2026-07-16
Due
2026-08-15
Remaining
4 days

Extends to 45 days if the consumer supplies additional relevant information inside the window, or if the dispute follows a free annual file disclosure under FCRA 612(a).

State transitions

  1. 2026-07-14 09:12:04Zintakedisclosure.deliveredCROA 1679c
  2. 2026-07-14 09:41:55Zdisclosure.deliveredcontract.signedCROA 1679d
  3. 2026-07-16 00:00:00Zcontract.signedwork.authorisedCROA 1679e
  4. 2026-07-16 14:03:19Zwork.authoriseddispute.sentFCRA 611(a)(1)
  5. 2026-07-21 11:20:08Zdispute.sentinvestigation.openFCRA 611(a)(2)

Attached documents

  • consumer-credit-file-rights.pdfStatutory disclosuresha 9f1c0a4e 41 KB
  • service-agreement-signed.pdfWritten contractsha 2b77de10 188 KB
  • notice-of-cancellation.pdfCancellation form, in duplicatesha c40a9b62 38 KB
  • dispute-letter-CRA-02.pdfDispute, certifiedsha ea3316d8 96 KB

Audit entries

  • 2026-07-16 14:03:19Zseat/di.okafordispute.sentCertified article 7019 8400 0002 6631 4192
  • 2026-07-16 14:03:19Zsystemclock.startedFCRA 611(a)(1)(A) 30 days, due 2026-08-15
  • 2026-07-18 08:02:00Zsystembilling.blockedCROA 1679b(b): no fee is billable before the service is fully performed
  • 2026-07-21 11:20:08ZCRA-02furnisher.notifiedFCRA 611(a)(2), 5 business days, met on day 3
Identity is tokenised in the record. Only the operator seat that opened the case can resolve it.Placeholder identifiers, demo tenant underwrite-demo

A warning is not a control

Most systems tell an operator afterwards that something was out of order. These five refuse the action instead, name the rule that refused it, and write the refusal into the trail. The full set runs to ten.

  1. CTL-001

    No fee before performance

    An invoice cannot be issued against a service line until that line reaches a performed state with evidence attached. The billing call returns 409 and names the unperformed line. There is no override flag, because an override flag is the thing an examiner asks about first.

    blocksCROA 1679b(b)
  2. CTL-002

    Disclosure before contract

    The contract object will not create until a delivered receipt exists for the separate written statement of Consumer Credit File Rights Under State and Federal Law. The receipt carries the document hash the consumer actually received.

    requiresCROA 1679c
  3. CTL-003

    Three business day cancellation hold

    Every outbound action on a new case is queued, not sent, until the third business day after signature closes. The hold is visible on the case, counts business days against the operator calendar, and is written into the audit trail as a hold rather than as a delay.

    holdsCROA 1679e
  4. CTL-004

    Contract completeness

    The generated contract fails validation if any required term is absent: payment terms, service description, estimated performance date, operator name and business address, and the conspicuous notice of the right to cancel with the cancellation form in duplicate.

    requiresCROA 1679d
  5. CTL-005

    Statutory clock, not a reminder

    The clock is a first class field on the case with a rule reference, a start evidence pointer, and a due date. It cannot be edited by a seat. It can only be extended by recording the event that extends it, and the extension names its own rule.

    recordsFCRA 611(a)(1)

All ten controls

Dispute lifecycle

The machine, with the clock printed on every transition

This is not a friendly numbered path. It is the state machine the platform actually runs, and each arrow carries the statute that governs it and the deadline that statute imposes. Those values are frozen: no tenant configuration can restyle a deadline.

Intake

state.intake

Consumer record opened. No fee is billable and none can be recorded.

Disclosure delivered

Before contractCROA 15 U.S.C. 1679c

The statement of Consumer Credit File Rights Under State and Federal Law is served as a separate document and its signed receipt is retained.

Disclosure delivered

state.disclosure

The separate written statement of Consumer Credit File Rights Under State and Federal Law has been served and its delivery is stamped.

Contract signed

Before any serviceCROA 15 U.S.C. 1679d

The written contract carries the terms of payment, the services, the estimated date of performance, the operator name and business address, and the conspicuous cancellation notice.

Contract signed

state.contract

A written contract exists, with the cancellation notice attached in duplicate.

Cancellation window

3 business daysCROA 15 U.S.C. 1679e

The consumer may cancel without penalty or obligation. The engine holds every outbound action for the duration and records the hold.

Cancellation window

state.cooling

Three business days in which the consumer may cancel without penalty. Work is held.

Work authorised

On expiryCROA 15 U.S.C. 1679b(b)

Work unlocks. Billing does not: no fee may be charged or received before the service to which it relates is fully performed.

Work authorised

state.authorised

The window closed without cancellation. Dispute preparation unlocks.

Dispute sent

Operator SLAFCRA 15 U.S.C. 1681i(a)(1)

Dispute despatched with the basis stated. Proof of despatch is attached to the record before the state is allowed to change.

Dispute sent

state.sent

Dispute despatched to the consumer reporting agency, with proof of despatch attached.

Investigation open

5 business daysFCRA 611(a)(2)

The agency must give notice of the dispute to the furnisher within five business days of receipt. The record tracks the date the notice is evidenced.

Investigation open

state.investigation

The statutory reinvestigation window is running and is displayed on every queue.

Results delivered

30 daysFCRA 611(a)(1)(A)

The reinvestigation window. It extends to 45 days if the consumer supplies additional relevant information during the period, or where the dispute follows a free annual file disclosure under FCRA 612(a).

Results delivered

state.results

Written results received. The record now holds an outcome for each disputed item.

Method of verification

15 daysFCRA 611(a)(7)

On request, the agency must describe the procedure used to determine accuracy, including the business contacted, within fifteen days.

Consumer statement filed

No deadlineFCRA 611(b)

If the dispute is not resolved to the consumer satisfaction, the consumer may file a statement of the dispute. The agency may limit it to one hundred words.

Closed

On outcomeFCRA 611(a)(5)(A)

Information found inaccurate, incomplete or unverifiable is deleted or modified. Reinsertion requires written notice to the consumer within five business days.

Method of verification

state.mov

A description of the procedure used to determine accuracy has been requested.

Consumer statement filed

state.statement

The consumer exercised the right to add a statement of dispute to the file.

Closed

state.terminal

Deleted, modified, verified or withdrawn. The case is sealed and stays exportable.

A case is three layers of paper and the stamps between them

Correspondence, response, outcome. Each layer carries its own timestamp, its own hash and its own evidence, and the outcome never overwrites the correspondence that produced it. Separate the stack to read all three.

  • Every layer is written once and referenced afterwards, never edited.
  • Document hashes are recorded at the moment of delivery, not at the moment of filing.
  • An export is generated from the trail, not from the current state of the record.

How the audit trail is built

CR-2026-04187, three layers, most recent on top

CorrespondenceDOC-88141

Dispute despatched to CRA-02, certified, with the basis stated and the tradeline identified.

  • 4 pages
  • sha 9f1c0a4e
  • certified 7019 8400 0002 6631 4192
ResponseDOC-88477

Written results of the reinvestigation received on day 26 of the thirty day window.

  • 2 pages
  • sha 41b0c7a9
  • received inside window
OutcomeOUT-04187

Date of last activity modified. The tradeline itself remains reported. The record states the change, not a promise.

  • item 1 of 1
  • modified
  • clock closed at 26 days

Six hundred rows, one under the rule

The correspondence queue is the surface an operator lives in. Point at a row, or tab to it, and it locks under a rule with its detail surfaced beside the table. The layout does not move, because a table that reflows while you read it is a table you stop trusting.

Correspondence, all open cases, most recent first
MessageCaseChannelSentDueRuleState
CR-2026-04187Certified mail2026-07-162026-08-15FCRA 611(a)(1)(A)Due in 4d
CR-2026-04188Certified mail2026-06-292026-07-29FCRA 611(a)(1)(A)Overdue 37d
CR-2026-04156Secure upload2026-08-112026-08-18FCRA 611(a)(6)Cleared
CR-2026-04156Certified mail2026-08-122026-08-27FCRA 611(a)(7)Due in 15d
CR-2026-04203Portal2026-08-182026-08-18CROA 1679eCancelled
CR-2026-04211Furnisher channel2026-08-202026-08-27FCRA 611(a)(2)Open

Case management

Implementation notes

These are implementation notes, not testimonials. There is no rating on this page, no logo wall and no customer count, because none of those would tell a compliance officer anything. Each operator below agreed to be named alongside what went wrong.

  1. Northgate Credit Services

    Director of compliance, 14 seats, 2 states

    Migrated from
    Two shared spreadsheets and a mail merge
    Onboarding
    11 working days
    What broke
    Business day counting across a state holiday calendar

    We had the disclosures. What we did not have was proof of when they went out. The migration surfaced 62 cases where the delivery receipt was missing, which was uncomfortable and correct. The cancellation hold miscounted a state holiday in week two and we had to reissue four notices.

  2. Baylor Ridge Financial Coaching

    Operations lead, 6 seats, 1 state

    Migrated from
    A general purpose CRM with custom fields
    Onboarding
    6 working days
    What broke
    Duplicate consumer records on import

    The clock being uneditable was the argument internally. Our old setup let anyone move a due date, so nobody trusted the queue. Import created duplicates for anyone whose file had two address spellings and we spent a day merging by hand.

  3. Calder and Wynn Consumer Advocacy

    Managing partner, 23 seats, 5 states

    Migrated from
    An in house Rails application
    Onboarding
    5 weeks, phased by state
    What broke
    Our own historical audit gaps

    We migrated 940 open cases. Roughly 30 of them could not be reconciled to a start evidence document, so they came in flagged rather than silently dated. That is the behaviour we wanted, but it did mean explaining the flags to two clients.

  4. Prairie Line Credit Group

    Compliance officer, 9 seats, 3 states

    Migrated from
    A dispute letter generator plus email
    Onboarding
    9 working days
    What broke
    Nothing during the cutover. Plenty during the dry run

    The dry run rejected our contract template three times before it passed, each time naming the missing term. That was the whole value of the exercise. The template we had been using since 2022 was missing an estimated date of performance.

Scope

What this platform will not do

  • Remove accurate information

    Nothing can. FCRA 611 addresses information that is inaccurate, incomplete or unverifiable. Accurate, complete and verifiable information stays on the file until it ages off under the FCRA time limits.

  • Promise an outcome

    Outcomes belong to the reporting agency and the furnisher. The platform guarantees process and evidence, and it will not generate a document that promises a result on an operator behalf.

  • Give legal advice

    The controls encode the obligations as written. Whether a given procedure satisfies them in a given state is a question for your counsel, and the compliance review service is run with your counsel in the room.

  • Stand between a consumer and a free dispute

    Consumers may dispute directly with each consumer reporting agency at no cost, and may obtain a free annual file disclosure atannualcreditreport.com. Every disclosure the platform generates says so.

See it against your own procedure

A demo runs on a sandbox tenant with your contract and disclosure templates loaded. It usually finds a missing term. That is the point of it.

Request a demo+1 (512) 402-7719