Not if the bank has an existing relationship with the consumer, which entitles them to access to the consumer's credit report.
The issue under the FCRA is the stated permissible purpose of the inquiry under one or more provisions of section 604. The FCRA does not use the terms "hard" or "soft" inquiry.
All permissible purposes entitle the inquiree to the entire credit report except for the permissible purpose under section 604(c), which relates to requests in connection with any insurance or credit transaction NOT initiated by the consumer, and for the purpose of making a firm offer for credit or insurance. Such promotional offers for credit only entitle the inquiree to the consumer's name and address.
If an inquiree makes an inquiry that is coded as a "soft" inquiry, they still see the consumer's full credit report unless it relates to a promotional offer for credit.
