If credit reporting agency does a pre-screening and for those qualified solicitation is done verbally, must the firm offer of credit (including prescreened opt out notices) still be provided in written form or can it also be provided verbally in this case as there is no written solicitation as stated by the FCRA?

There are no provisions to make the firm offer of credit orally.

What do you mean by that? That there are no specifications when firm offer of credit is given verbally?

And why do you think that is? Is it because there are no provisions for a verbal offer?

You're going to have a Regulation B retention issue as how to maintain oral records?

12(b)(7) Preapplication marketing information.

1. Prescreened credit solicitations. The rule requires creditors to retain copies of prescreened credit solicitations. For purposes of this part, a prescreened solicitation is an “offer of credit” as described in 15 U.S.C. 1681a(1) of the Fair Credit Reporting Act. A creditor complies with this rule if it retains a copy of each solicitation mailing that contains different terms, such as the amount of credit offered, annual percentage rate, or annual fee.

My husband's credit union violated that one, big time. It was either that, or they violated the prohibition on pulling a credit report to use for marketing purposes. This happened a couple of years ago. I decided to try out the CFPB complaint process and discovered that if a state chartered credit union violates a regulation, good luck in getting anyone to do anything about it. The State agency and the FTC were non-responsive.