We are only pulling new reports if the prior report is older than 90 days. If it is within 90 days, we are simply giving another copy of that credit score disclosure. This procedure is based on the thought that not a tremendous amount of information can change in 90 days, and the fact that our system for pulling reports has always asked us if we just want to re-print the "current" report if it is within 90 days.
I'm not certain that it is impermissable under the FCRA. Where in the FCRA are you getting that impression?
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Me, Type A? Maybe - I'm not done analyzing it yet.