No.
The FCRA provides a special service to creditors by permitting them to submit a statement of specific criteria to a CRA, and then obtain a listing of consumers whose credit files currently meet the specified criteria. That then permits creditors to make unsolicited offers of credit only to consumers who are likely to meet or exceed their minimum criteria. Such promotional inquiries preclude the CRA from providing any account specific information. It is only if the consumer then bites on the offer and applies that the creditor then obtains permissible purpose to pull their complete credit report.
Opting out is a specific notice sent to a CRA by a consumer that thereafter prevents that CRA from including the consumer in any such listings requested by creditors.
Existing creditors already have clear permissible purpose to pull a complete credit report from existing customers for purpose of reviewing their performance. They do no need to obtain CRA screening against criteria submitted to them, and can obtain a full credit report.
Opting out does not prevent internal account review pulls by existing creditors, who have their own, complete access.
