Disclaimer. This template is for use under attorney supervision. The General Counsel is the policy owner; do not modify the template language without GC approval. Adverse-action sequencing is strict: the Pre-Adverse Action Notice must be sent before the final decision is communicated, the candidate must be given a reasonable waiting period to dispute (Neuroscale’s standard is at least seven (7) business days, never less than five (5)), and only then may the Final Adverse Action Notice be sent. Skipping or compressing this sequence is a per-violation FCRA exposure (15 U.S.C. § 1681b(b)(3); § 1681m(a)).
How to use this template. This page contains two letters: (1) the Pre-Adverse Action Notice and (2) the Final Adverse Action Notice. Generate two separate letters by replacing the variables listed at the bottom of this page. Attach to each letter (a) a copy of the consumer report and (b) the CFPB-published “Summary of Your Rights Under the Fair Credit Reporting Act” (also attached at the time of Form A in the Background-Check Consent packet). Operational sequencing, the dispute-window calculation, and adjudication standards are in the Background Checks Procedure; personnel-security context is in the HR Security Policy.

LETTER 1 — PRE-ADVERSE ACTION NOTICE

Send before any final adverse decision is communicated. 15 U.S.C. § 1681b(b)(3)(A). Date: {{decision_date}} To: {{candidate_name}} {{candidate_address}} Re: Position of {{position_title}} — Conditional Offer Dated {{date_of_offer}} Dear {{candidate_name}}, Thank you for your interest in NEUROSCALE LLC (“Neuroscale”) and for your participation in our pre-employment review process. As you previously authorized, Neuroscale obtained a consumer report about you from {{cra_name}} for employment purposes. Neuroscale is considering taking adverse action — namely, withdrawing the conditional offer of employment for the position referenced above — based, in whole or in part, on information contained in that consumer report. No final decision has been made at this time. Enclosed with this letter you will find: a. A complete copy of the consumer report Neuroscale received about you; b. A copy of “A Summary of Your Rights Under the Fair Credit Reporting Act,” published by the Consumer Financial Protection Bureau; and c. Where applicable, any state-specific notices required by the laws of your state of residence or the state in which the position is based (see addenda below). The information in the consumer report that Neuroscale is considering as the basis for adverse action is, in summary: {{specific_information_basis}}. Your right to dispute. You have the right to dispute the accuracy or completeness of any information in the report directly with the consumer reporting agency. The contact information for {{cra_name}} is:
{{cra_name}} {{cra_address_phone}}
You also have the right to provide Neuroscale with any information you believe is relevant, including any explanation, mitigating circumstances, or evidence of inaccuracy. Neuroscale will not make a final decision for at least seven (7) business days from the date of this letter, in order to give you a reasonable opportunity to respond. Please direct any response to people@neuroscale.ai or to the recruiter named on your conditional offer letter. If you do not contact Neuroscale or the CRA within that period, Neuroscale may proceed to make a final decision and, if adverse, will provide you with a Final Adverse Action Notice in accordance with the FCRA. This letter is not a final decision, and the conditional offer remains conditional pending the outcome of this process. Sincerely, NEUROSCALE LLC People Operations people@neuroscale.ai Enclosures: Consumer report; Summary of Your Rights Under the FCRA; state-specific notices (as applicable).

LETTER 2 — FINAL ADVERSE ACTION NOTICE

Send only after the dispute window has closed and the decision has been made. 15 U.S.C. § 1681m(a). Date: {{decision_date}} To: {{candidate_name}} {{candidate_address}} Re: Position of {{position_title}} — Final Decision Dear {{candidate_name}}, This letter follows our Pre-Adverse Action Notice dated {{pre_adverse_letter_date}} regarding the consumer report obtained about you from {{cra_name}} in connection with your application for the position referenced above. After review and consideration of any information you provided, NEUROSCALE LLC has made a final decision to take adverse action, namely, to withdraw the conditional offer of employment for the position of {{position_title}} dated {{date_of_offer}}. This decision was based, in whole or in part, on information contained in the consumer report. In accordance with the Fair Credit Reporting Act (15 U.S.C. § 1681m(a)), Neuroscale provides the following notices: a. Identity of the consumer reporting agency. The consumer reporting agency that furnished the report is:
{{cra_name}} {{cra_address_phone}}
b. The CRA did not make the decision. The consumer reporting agency named above did not make the decision to take adverse action and is unable to provide you with the specific reasons for the decision. c. Your right to a free copy of the report. You have the right to obtain a free copy of the consumer report from the CRA named above, provided that you request the copy within sixty (60) days of receiving this notice. d. Your right to dispute. You have the right to dispute, directly with the consumer reporting agency, the accuracy or completeness of any information in the report. e. Right to additional disclosures. You have the right to obtain additional disclosures from the CRA under 15 U.S.C. § 1681g, including the right to know all information in your file (with limited exceptions), the source of the information, and a list of recipients of the report. Enclosed is a copy of “A Summary of Your Rights Under the Fair Credit Reporting Act” for your reference, along with any state-specific notices required by the laws of your state of residence or the state in which the position was to be based. We appreciate your interest in Neuroscale and the time you invested in our process. Sincerely, NEUROSCALE LLC People Operations people@neuroscale.ai Enclosures: Summary of Your Rights Under the FCRA; state-specific notices (as applicable).

State-Specific Addenda

Append as additional pages to one or both letters where the candidate resides or the position is based in the corresponding jurisdiction.

A. California

Pursuant to the California Investigative Consumer Reporting Agencies Act (Cal. Civ. Code §§ 1786 et seq.) and the California Consumer Credit Reporting Agencies Act (Cal. Civ. Code §§ 1785 et seq.): a. You have the right to obtain a free copy of any investigative consumer report or consumer credit report from the CRA, in addition to the federal sixty-day right described above. The CRA’s California-specific contact and rights summary are available on its website. b. You have the right to inspect, in person and during normal business hours, the files maintained on you by the CRA, upon presentation of proper identification. c. California Fair Chance Act (Cal. Gov. Code § 12952). Where the adverse action is based on a conviction history, this notice is provided as part of the individualized assessment required under the Fair Chance Act. You have at least five (5) business days from receipt of the Pre-Adverse Action Notice to respond, including the right to provide evidence of rehabilitation or mitigating circumstances. Where this Final Adverse Action Notice follows that process, Neuroscale has considered, at minimum: (i) the nature and gravity of the offense; (ii) the time elapsed since the offense and completion of the sentence; and (iii) the nature of the position sought.

B. New York / New York City

Pursuant to the New York Fair Chance Act (NYC Admin. Code § 8-107(11-a)) and Article 23-A of the New York Correction Law: a. The Pre-Adverse Action Notice was accompanied by a copy of the report, a written copy of Neuroscale’s Article 23-A analysis, and a Fair Chance Notice. The waiting period before this Final Adverse Action Notice was at least five (5) business days, during which the position was held open. b. The factors Neuroscale considered are: (i) the public policy of New York to encourage the licensure and employment of persons previously convicted; (ii) the specific duties of the position; (iii) the bearing, if any, the conviction has on fitness or ability to perform the duties; (iv) the time elapsed since the offense; (v) the age at the time of the offense; (vi) the seriousness of the offense; (vii) information regarding rehabilitation; and (viii) Neuroscale’s legitimate interest in protecting property, safety, and welfare.

C. Massachusetts

Pursuant to M.G.L. c. 6, § 172 and 803 CMR 2.00: a. Where the basis for adverse action includes a Criminal Offender Record Information (“CORI”) report, a copy of that report is enclosed. b. Neuroscale has provided you with the opportunity to discuss the CORI report and to dispute its accuracy. The procedure for disputing the accuracy of a CORI report with the Department of Criminal Justice Information Services is described in the materials enclosed.

D. Oregon

Pursuant to ORS 659A.320 and the Oregon Job Opportunities and Basic Skills Act, you have the right to be informed of the basis of any decision made on the basis of credit history information. You may obtain a copy of any report from the CRA at no cost.

E. Washington

Pursuant to RCW 19.182.040 and the Washington Fair Chance Act (RCW 49.94), you have the right, upon written request to the CRA within sixty (60) days, to a copy of any investigative consumer report and a written summary of your rights under chapter 19.182 RCW. Where the basis for adverse action includes criminal history, Neuroscale has conducted an individualized assessment as required by RCW 49.94.

F. New Jersey

Pursuant to the New Jersey Opportunity to Compete Act (N.J.S.A. 34:6B-11 et seq.), where the adverse action is based on criminal history, Neuroscale has determined that the conviction is reasonably related to the duties of the position, taking into account the factors enumerated in N.J.S.A. 34:6B-14.

G. Other States

Additional state-law obligations may apply (e.g., Maine, Vermont, Connecticut, Illinois, Colorado, Hawaii, the District of Columbia, Minnesota). Refer to the state-by-state matrix in the Background Checks Procedure and consult General Counsel before issuing the Final Adverse Action Notice in a jurisdiction not enumerated above.

Variables

VariableDescription
{{candidate_name}}Full legal name of the candidate
{{candidate_address}}Candidate’s mailing address (use the address on file from the application/onboarding packet)
{{position_title}}Title of the position for which the candidate was considered
{{date_of_offer}}Date of the conditional offer letter
{{cra_name}}Legal name of the consumer reporting agency (Neuroscale’s standard CRA is Checkr, Inc.)
{{cra_address_phone}}CRA’s mailing address and toll-free phone number, on a single line or block
{{specific_information_basis}}Concise, factual summary of the report content under consideration — drafted by People Operations with HR Security and General Counsel review (e.g., “a felony conviction for [offense] reported on [date]“)
{{decision_date}}Date the letter is sent — for the Pre-Adverse Notice, the date adjudication concludes; for the Final Adverse Notice, the date after the dispute window closes
{{pre_adverse_letter_date}}(Final Adverse Notice only) The date of the Pre-Adverse Action Notice previously sent to the candidate — typically at least 7 business days earlier

Cross-References

  • Background Checks Procedure — adjudication matrix, dispute-window calculation, and the state-by-state addenda matrix.
  • HR Security Policy — personnel-security control objectives and the obligation to conduct lawful pre-employment screening.
  • Background-Check Consent Form — the upstream Disclosure (Form A) and Authorization (Form B) that must be executed before any consumer report is obtained.
  • Data Subject Rights Procedure — handling of any subsequent CCPA/state-privacy requests by the candidate concerning their consumer report data.

Version history

VersionDateDescriptionAuthorApproved by
1.0May 8, 2026Initial versionCameron WolfeIshan Jadhwani