No, unsolicited offers for credit do not always occur based on info from a CRA.
The FCRA establishes a service to creditors who do not want to send mass mailings of offers for credit to consumers who likely will not qualify.
Creditors can send specified criteria to a CRA and obtain a listing of only consumers who meet the stated criteria, thus increasing the chances of qualification should the consumer then apply. Offers made based on a listing provided by a CRA are considered to be "firm offers for credit," which are defined in the FCRA as offers that must be granted if the consumer applies and is found, based on a full credit report, to still meet the stated criteria.
Creditors can also obtain consumer names and addresses by many other means without obtained a screening listing from a CRA.
Such offers will not refer to their name having been obtained from a listing provided by a CRA, and are not considered as a "firm offer for credit" as defined in the FCRA.
As for minors, the CARD Act provides specific qualification requirments for credit card offers to those under the age of 21.
Basically, it requires that the minor either have a co-signor that is at least 21, or first provide a showing to the potential creditor of their independent means to handle the potential debt.
