Quote Originally Posted by CreditGuy View Post
If a broker brings them a file with a third party report and they tell the broker they won't proceed based upon any of the data in said report, that is a credit determination and subsequently a violation of FCRA. Funding the loan or making an affirmative credit decision isn't what makes them subject to FCRA, making a credit determination based on report data does.
How is it a violation if they are not make a credit determination but only offering a preapproval based on information received. They will then do a credit pull when the merchant agrees to the preapproved terms.