Blessed are the marketers. The fact is this proposal at this stage isn't really a FCRA, Reg Z, or privacy issue. Of course, proper disclosure of APRs is required. I know of nothing that prohibits the practice of verbally offering credit via telemarketing. I'm sure the base of prospective borrowers would be pre-determined. The prospective borrower would not be obligated until they signed the check and any other disclosures appropriate for the credit. This is a variation of offers via the mail involving checks that once you endorse and acknowledge become binding.
Allan D. Virr, CRCM,CRP
Compliance Audit Solutions, LLC