jmbfl wrote:
Cheddar -
Can you post some links to the information you cite? I would like to read the opinion letters.
Certainly. Here are three that I have bookmarked. Keep in mind that I am not maintaining that the OP's city had PP to pull a report for registering a vehicle; nor am I arguing that these letters support any such position. I am simply illustrating the fact that PP is not limited to credit-related transactions, as many people seem to think.
"For example, a landlord to whom a consumer applies to rent an apartment, a bank to which a consumer applies to open a checking or savings account, or a merchant to whom a consumer offers a personal check as payment for goods or services has a 'permissible purpose' to obtain a consumer report under this provision."
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"Section 604(a)(3)(F) allows a person to obtain a consumer report in connection with non-credit transactions. Section 604(a)(3)(F)(i) provides a permissible purpose on behalf of a party who has a legitimate business need for a report 'in connection with a business transaction that is initiated by the consumer.' Thus, for example, a merchant may procure a report on a consumer who offers to pay for goods with a personal check. Section 604(a)(3)(F)(ii) provides a permissible purpose for a party that has a legitimate business need in connection with an ongoing relationship 'to review an account to determine whether the consumer continues to meet the terms of the account.' Thus, a financial institution may obtain a report on an existing checking or savings account customer."
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"The dealer may also obtain a report to check a consumer's creditworthiness when the consumer presents a personal check to pay for the vehicle. By contrast, a permissible purpose would not arise if a consumer intends to pay by cash."