First and foremost, in the eyes of the FCRA, the inquiree either has a permissible purpose or they dont. With the exception of promotional offers for credit not initiated by the consumer, the FCRA places zero restrictions on coding of inquiries. The terms "hard" or "soft" inquiry are not mentioned in the FCRA.
Coding of inquiries is purely an administrative concoction of the CRAs, and its inner workings remain, at least to me, a total mystery.
There are clearly certain types of inquires that have associated codes that restrict their viewing by others in your credit report, such as pulls of your own CR, and internal account reviews by existing creditors. Ergo, they are not consdered by FICO, and are "soft" under establised practice.
The FCRA provides permissible purpose for business entities not involved in the extension of actual credit to a consumer to pull your credit report, provided they have a "legitimate business purpose" for that information. FCRA 604(a)(3)(F). So, the mystery of what codes are provided for that purpose arises. Do the CRAs provide two alternate codes, one stating "legitimate business purpose, but dont include in the consumer's credit report" and another for "legitimate business purpose, no CR exclusion"? If so, are businesses, who arent usually involved in credit reporting, saavy to those distinctions?
Is a business entity even required to provide ANY coding along with their inquiry? If not, then how does the CRA make the distinction? Maybe the inquiree is not even part of the HP vs SP determination.
A huge mystery to me. I have never seen an answer from any reliable source, such as the CRAs.
