Re-use Credit Report for New Appl for Credit?

We can pull a credit report if we have a permissible purpose (ex: an application for a mortgage loan) but we cannot re-use that credit report to cross-sell the applicant on a different product (ex: a HELOC) that the applicant did not apply for. This would be impermissible under FCRA and would constitute a violation. We would also breach our contract with the credit bureau.

BUT . . . If the applicant applies for a mortgage loan and then 3 months later applies for a HELOC, may we re-use the existing credit report for the HELOC application? Is this permissible because we have a “new” permissible purpose (via a second application for the HELOC)? Does the second application give us a new permissible purpose to re-use the credit report already in file?

This is an age-old debate. Likely, your contract with the credit bureau would prevent that. Plus, who would want to as a lot can change in three months. Sounds like a dereliction of credit underwriting duties to me.