Typically, I believe so. Everyone I have had was a hard pull. I suppose it depends on the lender and the purpose though.
Almost always a HP for new credit.
The only issue under the FDCPA is if the inquiry was permissible. Application for new or additional credit always has express permissible purpose, as do reviews of accounts by your current creditors. Two examples of every day permissible purpose that are treated differently based on practice, not statute or regulation.
The issue of hard vs soft is an administrative coding issue. It is common practice that inquiries by your creditors to conduct a review of your account on their own, when not related directly to a consumer initiated request for new or additional credit, are coded as soft. Creditors seem to comply with this practice.
Any inquiry that is based on a consumer initiated request for new or additional credit is fair game, and in my opinion should be, coded as "hard."
That is the primary intent of even including inquiries in consumer credit reports.... so others can see your attempts for addtional credit.