Well, on a legitimate inquiry, I think that you could justify that you had a permissible purpose.
Documentation and being able to standardize that within the organization is probably the biggest hurdle. It would be necessary in order for the bank to audit appropriately to ensure that the inquiry was legitimate, the information was used appropriately, and proper action was taken based on the information obtained and communicated.
As such, most banks have a no application - no credit report policy. It is too hard to manage otherwise.
If someone is asking about loan products, employees are trained to say, if your credit score is in the range of XXX then our current pricing would be XXX. This can vary of course based on your actual credit score and other factors.
The biggest issue that you are going to find is that officers are using these credit reports to prescreen applicants and there is a failure to provide proper adverse action notices and potentially the outright discouragement of applications from being submitted. Those are very dangerous areas to venture into.
Also, check your CRA contract and see if it outlines specific permissible purpose limitations.
The opinions expressed here should not be construed to be those of my employer: PPDocs.com