Firm Offer of Credit mailers for auto dealers, explained
What is a firm offer of credit mailer?
Why you can mail people who never applied
What a compliant firm offer must include
Who's responsible for what
We handle
You approve & own
Firm offer questions, answered
What is a firm offer of credit?
Under the FCRA (15 U.S.C. §1681a(l)), a firm offer of credit is an offer that will be honored if the consumer continues to meet the criteria used to select them. It’s what lets a dealer use bureau prescreen data to mail consumers a real, prescreen-based credit offer. Educational, not legal advice.
Why can I mail people who never applied at my store?
Because the FCRA permits prescreened solicitations for the purpose of a firm offer of credit (§1681b(c)(1)), as long as the consumer hasn’t opted out. The firm offer is the permissible purpose — you’re extending a genuine offer, not just advertising.
Is Soft Pull Mailers a credit bureau?
No. Soft Pull Mailers is a dealer-facing program; the underlying credit data and prescreen infrastructure come from RMA Data Plus, a Full-End Service Provider for the national bureaus. You receive a managed program rather than assembling the bureau relationships yourself.
What disclosure has to be on the mailer?
A firm offer generally must carry the prescreen opt-out notice required by §1681m(d) — in the layered short and long form under CFPB Regulation V (12 CFR 1022.54) — plus the toll-free opt-out number and a statement that credit information was used to select the consumer. We build the notice into the piece; you approve the final creative. Educational, not legal advice.
How does a consumer opt out of prescreened offers?
Consumers can opt out of prescreened credit and insurance offers by calling 1-888-5-OPT-OUT (1-888-567-8688) or online at optoutprescreen.com, the official opt-out operated for the nationwide bureaus. Suppressing opted-out consumers is part of running a clean list.
What are the most common firm-offer mistakes?
The big ones: making a token “offer” with no real value, leaving off or shrinking the required opt-out notice, and not honoring the offer for consumers who still qualify. Keeping the offer bona fide and the disclosures intact is what keeps the program compliant. Confirm specifics with counsel.