I am in the process of an audit and happened to pull this as a part of my sample to ensure permissible purpose for pulling a credit report.
We had a customer come in to inquire about qualifing for a loan. The loan officer pulled a credit report and after a glance (huge problems on the report), stated to the customer that he would have to clean up some of the issues on his credit report before he would be able to qualify for a loan.
No actual application. How do you document this for FCRA purposes and how long should we keep it?
Do you have a file for pre qualification inquires that you keep for 25 months.

I believe the loan officer turned this "inquiry" into a "denial". Read the definition of "application in Reg B (and it's commentary). The loan officer basically told this person "no".

You don't need an "actual application" to pull a credit report. You should retain all documentation that the loan officer had (SSN, etc.), send an adverse action notice and keep all for 25 months.

Agreed. He reviewed information and made a decision. This is well beyond the inquiry stage.