What is required in order to obtain a consumer's credit report is a matter of law, as defined in FCRA 604.
FCRA 604 has been in effect for decades, and clearly establishes that a party can obtain a consumer's credit report without any express permission of the consumer as long as they provide a statement that they have one or more of the permissible purposes, which are set forth within FCRA 604.
Section 604 was clearly intended to avoid the need for express consumer authorization, as that would bring the consideration and approval process for new credit, insurance, and many business transactions initiated by a consumer to a crawl or dead stop if consumer express approval were to be required.
The entire purpose of section 604 is to list permissible purposes that permit obtaining a consumer's credit report without need for their permssion. The law serves as the permission.
As for reference to some 90 day period, there is no such provision regarding credit inquirees.
