Permission from the consumer is only one way that access to a consumer's credit report is authoritzed.
The other, and more common, is by showing a permissible purpose, as defined under one or more sections of FCRA 604/
Otherwise, conduct of business and credit approval would come to a crawl pending attainment of permission for each inquiry.
Section 604(a)(3)(E) provides permissible purpose to a person who:
"intends to use the information, as a potential investor or servicer, or current insurer, in connection with a valuation of, or an assessment of the credti or repayment risk associated with, and existing credt obligation"
Congress apparently condiered the valuation of existng consumer accounts for which a party is considering investing or servicing as an important practice that should permit review of consumer reports.
AS to whether such an inquiry can be coded as sott, other than so-called promotional inquiries under subsection 604(c), the FCRA does not regulate the coding of inquiries such that they are not viewable by others. Whether coding as soft is mandated would depend unpon the guidelines of the CRAs.
Unfortunately, the coding of inquiries is not set forth in any publicly available publication by the CRAs.
However, it is clearly akin to an internal account review conducted by creditors, which is well known to be specified by the CRAs as a soft inquiry.
I would contact the CRA and inquiry as to their policy regarding such inquiires. If they should be coded as sott, then perhaps an incorrect code was somehow entered, and it could be recoded as soft, solving the problem of effect on credit scoring.
