If we obtain a credit report for a consumer's request for a non-real estate secured loan (like an auto loan), can we use information in that report to send a letter to the customer marketing our home equity products? The question has been posed to me under two circumstances:1) we do grant the initial request and therfore the applicant becomes a customer, 2) we don't grant the request, primarily because another lender beat us to the approval (indirect lending).
We would typically see a mortgage on the credit report, triggering the marketing of our HELOC product.

No, you cannot use the credit report for anything other than the permissible purpose for which you pulled the report. There is an FTC staff opinion letter that specifically says you cannot use a credit report pulled for one permissible purpose to market another one of your products.

Can you point me to this opinion? Thanks