A member moves to accept a prescreen offer, now what?

The NAFCU compliance team has written plenty of blogs on Fair Credit Reporting Act (FCRA) issues. Some of these blogs have explained the FCRA requires a permissible purpose before using information from a member’s consumer report. Occasionally, we receive questions about whether a credit union can postscreen members who have been sent a firm offer (often referred to as “prescreening”), along with questions about changing the terms of the offer once a member expresses interest. This blog focuses on the answers to these questions.

Postscreening for Verification

As a starting point, the requirements for prescreening members in order to make firm offers of credit are explained in the Federal Trade Commission’s (FTC) guide, 40 Years of Experience with the Fair Credit Reporting Act (40-Year Guide). As described in the 40-Year Guide, the FCRA:

  • explicitly authorizes prescreening;


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