Are there specific rules related to accepting credit applications by phone as it applies to generating a CRA report? It's my believe the FCRA Section 604 would apply but I can't interpret this section to give me rules for disclosing to consumer that a credit report may be obtained as part of the credit approval process. Consumer, if denied, would never physically sign the application authorizing the CRA report.

There are no signature requirements. If you have an application for a loan, you automatically have a permissible purpose to pull a credit report.