Firm Offer of Credit Mailers

Firm Offer of Credit mailers for auto dealers, explained

What a firm offer of credit mailer is under the FCRA, what a compliant one must include, and exactly what the dealer versus the vendor is responsible for. Plain English — educational, not legal advice.
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What is a firm offer of credit mailer?

A firm offer of credit mailer is a prescreened direct-mail solicitation sent to consumers who met credit criteria you set in advance. Under the FCRA (15 U.S.C. §1681a(l)), it must be a genuine offer that will be honored if the consumer still qualifies — and it must include the required prescreen opt-out notice. It's the framework that lets a dealer market with bureau credit data.

Why you can mail people who never applied

The FCRA limits who can use a consumer's credit information and why. Prescreened solicitations are a specific permissible purpose: §1681b(c)(1) allows a credit bureau to provide a prescreened list to a marketer for the purpose of making firm offers of credit, provided the consumer hasn't opted out. In other words, the firm offer is the reason it's permitted to mail consumers who never walked into your store — you're extending a real offer, not just advertising.
Courts have held that a firm offer must carry real value to the consumer — not a token designed only to generate leads. Keeping the offer bona fide is what keeps the program on solid footing.

What a compliant firm offer must include

A genuine offer of value the consumer can accept if they still qualify
Credit criteria set in advance, so the offer is truly prescreened
The prescreen opt-out notice required by §1681m(d) — in both the short and long (layered) form
The toll-free opt-out number (1-888-5-OPT-OUT) tied to the bureaus' opt-out system
A statement that credit information was used and the consumer was selected by meeting criteria
Notice that the offer may not be extended if the consumer no longer meets the criteria
This is a general summary of common firm-offer requirements under the FCRA and CFPB Regulation V (12 CFR 1022.54), not legal advice. Requirements are fact-specific — confirm your exact disclosures with qualified counsel before mailing.

Who's responsible for what

We handle

Prescreen data and list generation (via RMA) · building the offer to your terms · the required opt-out notice on the piece · variable-data print and mail fulfillment · returning responders to your CRM.

You approve & own

The credit criteria · the offer terms · honoring the firm offer for consumers who still qualify · your obligations as the FCRA “user” of the data. When in doubt, run the piece past your compliance advisor before it drops.
FAQ

Firm offer questions, answered

The Mailer

See exactly what lands in the mailbox

Every piece is variable-data printed and personalized to the recipient's vehicle, equity, and offer. Here's a real example.
$0.73
USPS
METRO HONDA
Scottsdale · AZ · Family-owned since 2003
Hi John —
You came into our showroom last month for a closer look at the 2026 CR-V Hybrid Touring. We put your numbers together and found something worth a second look: a payment plan that fits your budget, with your trade-in applied.
Your Personalized Offer
2026 CR-V Hybrid Touring · Est. $487/mo*
$0 down · 0.9% APR · 60 mo
Claim This Offer →
P.S. Your CR-V is one of the most-traded vehicles in our inventory this month — and your equity works in your favor. This offer expires 8/30. Reply or scan the code to lock it in.
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Run a compliant firm-offer program

We build the offer and the required disclosures; you approve the terms. Get a territory check and see a sample firm-offer mailer for your market.
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