Well, you still have to have a permissible purpose and that is pretty general boiler plate language, and I am not sure that complies with the FCRA. I think you would need specific written permission to pull credit. A consumer cannot just give a lender carte blanche permission to pull credit whenever they feel like it.
You could also not rely on the general "review" permissible purpose and if the borrower is not past due, you could not rely on the "collections" permissible purpose. On closed-end loans, the FTC has been pretty clear that a review purpose does not exist on closed-end credit.
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 â€œreviewâ€ permissible purpose.
Staff believes that the â€œreviewâ€ permissible purpose applies only where the creditor has an existing account relationship with the consumer and uses the report solely to decide whether to modify the terms of the account.
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