Global HandsAttestyx™by Global Hands, Inc.
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SAMPLE - DRAFT FOR COUNSEL REVIEW. Not yet executed by Global Hands, Inc. (Operator) or JIL Sovereign Technologies, Inc. (Licensor); not binding on any party.
For Grantors

FCRA Non-Applicability Statement

Why Attestyx is not a Consumer Reporting Agency under the Fair Credit Reporting Act.

Effective: 2026-05-04Last updated: 2026-05-04Version 1.0 (sample)

1. Statement

Global Hands, Inc. (the Operator) is not a Consumer Reporting Agency (“CRA”) under the Fair Credit Reporting Act, 15 U.S.C. § 1681 et seq. (“FCRA”), and the Verdict Engine, CREB attestations, and Bad-Actor Registry are not Consumer Reports.

2. Reasoning

The Platform's reports concern organizations (Grantees) and their authorized signers, beneficial owners, and personnel in their commercial / fiduciary capacity, not consumers in their personal credit, insurance, employment, or housing context. FCRA covers reports used or expected to be used or collected for the purpose of serving as a factor in establishing the consumer's eligibility for credit or insurance to be used primarily for personal, family, or household purposes; employment purposes; or any other authorized FCRA purpose. The Platform's reports do not serve such purposes.

3. Limitations

This statement is operational only and does not constitute legal advice. Foundations using the Platform's output to make decisions in FCRA-covered contexts (e.g. background-checking employees of grantees beyond the program-officer role) are responsible for compliance with the FCRA in such use.