I would like to know if we would we be required to provide a firm offer of credit according to FCRA if our customer list for a solicitation letter was based solely on consumers who live in certain states and had an inquiry on their credit report from a specific lender during the last XX months. The criteria for the consumer list wouldn't include their credit score or anything else.

Thanks

I know that some credit bureaus are selling this product. They claim that the reporting of a credit inquiry on a customer is not a consumer report. I have not seen the FTC nor a court opine on this yet.