![]() ![]() The postscreen is simply an opportunity to verify correct information was relied on in making the offer and ensure the member still qualifies once they attempt to accept it. This is not a second chance to qualify the member based on new criteria or an opportunity to have a deeper look at the member’s creditworthiness. Accordingly, once the offer is made and the member expresses interest in accepting it, a credit union may verify the information already considered to ensure the member qualifies for the credit. Under the FCRA, a firm offer of credit is one that will be honored by the credit union as long as the member continues to satisfy the specific criteria used to identify the member as someone who was qualified to receive the offer. (B) of the information in the consumer's application for the credit or insurance, to determine that the consumer meets the specific criteria bearing on credit worthiness or insurability. (A) that the consumer continues to meet the specific criteria used to select the consumer for the offer, by using information in a consumer report on the consumer, information in the consumer's application for the credit or insurance, or other information bearing on the credit worthiness or insurability of the consumer or “The term ‘firm offer of credit or insurance’ means any offer of credit or insurance to a consumer that will be honored if the consumer is determined, based on information in a consumer report on the consumer, to meet the specific criteria used to select the consumer for the offer, except that the offer may be further conditioned on one or more of the following: This postscreening is permitted because the FCRA’s definition of “firm offer of credit” states the firm offer may be conditioned on verification of the information relied on in sending the offer: requires specific disclosures in offers sent to members.ĭescribed in the second prong above, credit unions have limited opportunity to conduct postscreening after a firm offer has been sent. ![]() ![]() allows members to “opt out” of receiving prescreened offers and.“allows creditors and insurers the right to conduct limited ‘postscreening’ so that they can deny credit or insurance to consumers who no longer meet the creditworthiness or insurability criteria initially used to select them for the prescreened offer”.As described in the 40-Year Guide, the FCRA: This blog focuses on the answers to these questions.Īs a starting point, the requirements for prescreening members in order to make firm offers of credit are explained in the Federal Trade Commission’s (FTC) guide, 40 Years of Experience with the Fair Credit Reporting Act (40-Year Guide). Occasionally, we receive questions about whether a credit union can postscreen members who have been sent a firm offer (often referred to as “prescreening”), along with questions about changing the terms of the offer once a member expresses interest. Some of these blogs have explained the FCRA requires a permissible purpose before using information from a member’s consumer report. The NAFCU compliance team has written plenty of blogs on Fair Credit Reporting Act (FCRA) issues.
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