Our marketing department wants to create direct mailing lists to send loan solicitations. Their idea is to take an internal list, send it to a third party to collect household information, and use that information to solicit for a particluar loan product. In this situation, they are not collecting information that identifies credit-worthiness of the recipients.

Does FCRA and the firm offer of credit apply?

What household information?

They want to know if a student (over the age of 18) lives at the address.

I would say no under that scenerio.