A consumer's express permission is not required in order to pull their credit report.
The expreess purpose of FCRA 604 is to define certain situations where express permission is NOT required for a party to receive a onsumer's credit report. Otherwise, many credit apps and business transactions would come to a crawl.
One such purpose is when a consumer initiates a business transaction that would legitimately have need for the party to evaluate the consumer's credit report as part of that transaction.
Whether car shopping gives rise to a permissible pull thus depends upon the degree to which there is a recognized business transaction, not on whether the consumer provided express permission. The FTC has issued guidelines stating that car shopping itself does not legitimately give rise to permissible purpose unless/until there is some clear indication that the consumer intends to actually purchase a vehicle and/or seek potential financing.
How serious was your shopping?
