{"page":"/blog/fcra-prescreen-rules","modified":"2026-11-10","license":"https://creativecommons.org/licenses/by/4.0/","columns":["Pattern","Data source","FCRA question","Authority that speaks to it"],"rows":[["Prescreened list, mailed firm offer","Bureau file, screened for the lender","Standard prescreen: firm offer, notice, criteria kept","§ 1681b(c); § 1681m(d); § 1022.54"],["Prescreened list matched to online IDs and served as display or social ads","Same list, onboarded to a DSP or platform","Is each ad a \"written solicitation\"? Where does the short notice go in a banner? Does the matching vendor receive more than § 1681b(c)(2) allows?","Statute and rule text only; no CFPB statement found (open)"],["Bureau-derived \"marketing audiences\" sold to any advertiser, with no firm offer","Credit file attributes","Is the audience a consumer report furnished without a permissible purpose?","Trans Union v. FTC (2001); withdrawn CFPB proposal (89 FR 101402)"],["Bureau shows a merchant's ad to consumers it selects, without transferring the list","Credit file attributes, used by the bureau","Does using the file to deliver someone else's ad \"furnish\" a report?","Withdrawn CFPB proposal, § 1022.10(b)(2) as proposed; no rule in force (open)"],["Credit attributes aggregated to ZIP+4 or household","Bureau file, aggregated","When does aggregate data stop being information on a consumer?","Withdrawn CFPB proposal discussed three alternatives; no rule in force (open)"],["Lender's own customer data for its own offers","Transaction and experience data","Not a consumer report for the lender's own use; GLBA applies instead","§ 1681a(d)(2)(A)(i); see GLBA joint marketing exception"],["Affiliate's eligibility data used for a solicitation","Affiliate records","Regulation V affiliate marketing notice and opt-out","12 CFR § 1022.21"],["Mortgage trigger lead","Mortgage credit inquiry","Firm offer plus authorization, existing mortgage or existing account","§ 1681b(c)(4)"]],"sourceUrls":[["https://www.law.cornell.edu/uscode/text/15/1681b","https://www.law.cornell.edu/uscode/text/15/1681m","https://www.law.cornell.edu/cfr/text/12/1022.54"],[],["https://www.courtlistener.com/opinion/185510/trans-union-corp-v-federal-trade-commission/","https://www.federalregister.gov/documents/2024/12/13/2024-28690/protecting-americans-from-harmful-data-broker-practices-regulation-v"],[],[],["https://www.law.cornell.edu/uscode/text/15/1681a"],["https://www.law.cornell.edu/cfr/text/12/1022.21"],["https://www.law.cornell.edu/uscode/text/15/1681b"]]}