Human Trafficking Victim
Compliance Policy

Instructions for submitting a request to block adverse items resulting from Human Trafficking

We will need you to provide:

1. “Appropriate proof of identity” as part of your submission to us to request a block of adverse items of information that resulted from trafficking. Please provide as much information as possible!
       • First, Middle, Last Name
       • Any other or previously used names,
       • Current and/or recent full address (street number and name, apt. no., city, state, and zip code),
       • SSN
       • DOB
Additional proof of identity if needed. Copies of government-issued identification documents, utility bills, and/or other methods of authentication of a person's identity,

2. Trafficking Documentation. This is:

     a. Victim Determination Information
              i. Victim determination is generally defined as documentation of a determination that a consumer is a victim of trafficking, made by either:
               • a Federal, State, or Tribal governmental entity,
               • a court of competent jurisdiction, which includes certain documents filed in court;
               • a non-governmental organization or human trafficking task force, including victim service providers affiliated with these entities, authorized by a Federal, State, or Tribal government entity; or
               • a self-attestation by a consumer who identifies as a victim of trafficking that is signed or certified by a Federal, State, or Tribal government entity, court of competent jurisdiction, or an authorized representative of these entities.

     b. Identified adverse items of information. This is generally documents that identify items of adverse information that should not be furnished by us because the items resulted from a severe form of trafficking in persons or sex trafficking. An “adverse item of information” could include records containing derogatory information, such as payment delinquencies or defaults, records of coerced debt, records of criminal arrests and convictions, and records of evictions or non-payment of rent.

     c. A preferred means of written communication to you. This can be a mailing address or email address.
Please mail the above information to either of these mailing addresses:

The Cole Group                                     The Cole Group
10050 Northwest Freeway                 DEPT 209
Suite 300                                                PO Box 4458
Houston, TX 77092                               Houston, TX 77210

If you have questions regarding what to provide, please call us at 800-337-0165

An overview of the Human Trafficking Regulation can be found here:
https://files.consumerfinance.gov/f/documents/cfpb_fcra-trafficking_fast-facts.pdf