You don't have a permissible purpose without personal liability for a hard or a soft pull without specific written authorization. I am not even sure you have the right to pull credit for monitoring purposes on a commercial loan.
In a 1999 letter, the staff opined on this issue in the context of closed-end credit transactions. Because the terms of closed-end credit transactions are generally predetermined and thus may not be changed unilaterally by the creditor, the staff opined that the creditor in that instance did not have a “review†permissible purpose. FTC Informal Staff Opinion Letter, Apr. 9, 1999
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