If an applicant starts an real estate online application and a credit report is pulled prior to the applicant actually clicking the Submit Application button, are we in violation of FCRA? It doesn't appear we received a request for credit. I found a couple files like this while auditing and both only had skeletal information completed. I plan to reach out to the admin for the online program to inquire about the how the parameters/process was set up.

Without the applicant hitting submit, I see no permissible purpose.

The confirmation is helpful, thank you Randy!