FCRA,603(d)(2)(A)(i)-"...report containing information solely as to transactions or experiences between the consumer and the person making the report;" - financial institution is a mortgage loan servicer for a third party investor, is the servicing information used for credit marketing purpose by FI considered "transactions or experiences between the consumer and the person making the report?" Thus excluding the credit transaction from coverage by section 604(c), Furnishing Reports in Connection with Credit or Insurance Transactions that are not Initiated by the Consumer and 16 CFR; Part 642, Prescreen Opt-out Notice?

I don' understand your question? Are you saying that you service mortgage loans for third parties and you want to pull information from those files to directly market to those individuals??

If so, you most likely would be in violation of any servicing agreements you have signed as you would be violating the third party's privacy policies.

So other than violating the servicing agreement, would using such information be considered a consumer report and a prescreen transaction under the FCRA?

"So other than violating the servicing agreement,"

So that reason is not enough???? It would not be a credit report or prescreening. It would most likely be deemed the illegal use of consumer information obtained after agreeing to maintain consumer information confidential through agreements with your investors.