We do pre-qualifications (application for a purchase but no property address has been identified) and we use the same application; however, we have a designation in our LOS that flags it as such and will not ask for government monitoring information. Like you, we only pull credit and issue a credit only approval letter if the borrower requests one. The credit approval is based on the information stated in the application, and our letter says this. I have outlined this process in our procedures, and made sure to put emphasis on the fact that we do not conduct any comprehensive analysis of the applicant's creditworthiness, which includes income verifications and other matters typically reviewed as part of our normal income approval process.
My understanding is that as long as we do not have a "formal" preapproval program which includes income verifications, our "preapprovals" are still considered pre-qualifications.
Keep calm, and let the compliance officer handle it....