We utilize a credit pull at inital account opening as part of our way of identifying a new customer, per signed agreement (below).

Question - Can a Personal Banker pull credit on an EXISTING customer when opening a new/additional deposit product? The primary purpose would be for internal cross-selling purposes. Or would this violate FRCA/FACT? I'm not sure if this falls under the permissible use of "If authorized in writing by the consumer." (Please see final line of agreement language)

Agreement Language:

I/we authorize XXX to check my/our account, credit and employment history, to obtain customer credit reports from third parties, including credit reporting agencies, to make whatever inquiries it considers appropriate to determine my/our eligibility for the accounts or services I/we request, and to verify the identity of all account holders and authorized signers. In addition, I/we agree that XXX may utilize my credit report information for internal marketing and cross sell purposes.

I think you need to talk to your attorney that drafted that language. Cross selling is never a permissible purpose and getting written permission to pull such a report is very questionable. Not to mention it most likely violates your contract and current certifications with your credit reporting bureau.