Question Regarding CRTP Exceptions

[Anonymous]

a lender, a CC company for example, can see your full credit file if the transaction amount is $150K or greater.  when applying for a CC, there is no firm credit limit we apply for; the CC company looks at the CR and determines the limit.  is there anything that prevents them from pulling a consumer's full file under the $150K exception rule?  

obviously 99.99% of consumers are not eligible for a $150K credit line, but the CC company must know that if they say they might approve someone for that amount, then the CRA has no choice but to give the full credit file and all the items subject to CRTP would be viewed by the lender.

also, does a $150K+ INQ show up on the CR in a special way?

[RobertEG]

The governing exception is FRCA 605(b).  It exempts from the normal time limits under any section of FCRA 605(a) if the consumer credit report is to be reviewed in connection with:

"(1) a credit transaction involving, or which is resonably expected to involve, a principle amount of $150,000 or more;

 (2) the underwriting of life inurance involving, or which might reasonably be expected to involve, a face amount of $150,000 or more; or

 (3) the employment of any individual at an annual salary which equals, of may reaonably be expected to equal $75,000 or more."

Under the FCRA per se, there is no such thing as a "hard" or "soft" pull.  So-called hard and soft inquiries are merely credit reporting codes established by the CRAs to enable creditors and FICO scoring to evaluate how they wish to consider or score  inquiries.  There is no specific regultion of this coding under the FCRA, other than that all reporting must be accurate.  The CRAs dont challenge the reasons provided for pull of your CR.  I have never seen an inquiry code that differentates whether access to the consumer's credit file was more expansive due to an exercise by the creditor of the excception provision of FCRA 605(b).

[Anonymous]

good info robert, thank you.