Are opt-out notices required when sending pre-approval letters/solicitations to existing borrowers or individuals who do not already have a business relationship with the bank?

If these lists of customer have been derived from a pre-screened list from a credit bureau - then the credit bureau opt-out information would have to be provided. See FCRA 615(d).

Thanks...I have another question on the same topic dealing with affiliates. We purchased an independent mortgage company and they are our affiliate. If we chose to solicite the mortgage companies clients whome have no business relationship with the bank, I believe we would still have to send an opt-out notice. correct?

Actually, the mortgage company is going to have to comply with the new affiliate marketing opt-out requirements with all thier customers.

Does the same hold true for online processes, i.e. opening accounts online only after the individual has been pre-screened through online bureau prescreening? The same two paragraphs of pre-screening opt-out notices are required to be provided online just as in a snail mail offer aren't they?