No.
Prequalification is a credtior process, and is not itself governed by the FCRA. The opt-out provisions apply to offers that are not initiated by the consumer.
If you initiate a request, it is not covered under the so-called promotional offers provsision of the statute, and the associated opt-out provisions, as it provides them a seprate permissible purpose, and access to your entire CR.
The only reason that pre-qual is included in unsolicted promotional offers for which they obtained your name from the CRAs is that they cannot simply get your name for any offer for credit. Under the statute, it must be a "firm offer."
