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RMA pulls a HARD inquiry.. Can they do that?


Thomas1096
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Hey, My points with equifax went down due to a hard inquiry from RSKMGTJXAB

I know that has to be RMA. Yesterday I faxed them (have the report off of fax stating they received it) and plainly stated that they had to VALIDATE the debt and until I received it, it was illegal for them to continue collection... Why are they pulling a hard inq?

What can I do?

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They did a hard inquiry to see if you had money for them to collect.

Question is, did they do this before or after they took on the collection effort. If they did it before, you may have a case against them for not having a "permissable purpose" to view your reports. Search the site for references...

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They have a permissible purpose in connection with the connection of collection of a debt. There are mixed messages on this. Just because the FTC thinks pulling a report or placing a trade-line on there is continued collection, case law is what you need, unless the FTC is going to do enforcement action on your behalf (not likely). What district are you in ?

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They don't have a permissible purpose to pull a hard. They did have a permissible purpose to review your credit, though. See my next post for more.

FCRA 604©(3) defines a hard inquiry:

Information regarding inquiries. Except as provided in section 609(a)(5) [§ 1681g], a consumer reporting agency shall not furnish to any person a record of inquiries in connection with a credit or insurance transaction that is not initiated by a consumer.

FCRA 609(a)(5) defines a soft inquiry:

A record of all inquiries received by the agency during the 1-year period preceding the request that identified the consumer in connection with a credit or insurance transaction that was not initiated by the consumer.

The latter was put in there as a consumer protection measure to show who a consumer's reports were being delivered to.

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The act of whether or not a PP exists and how the report may or may not be used is different from how the fact of the inquiry is reported to the consumer and others.

As near as I can tell, there is no consumer cause of action against someone who codes a hard vs. a soft EXCEPT under the FDCPA (because saying that it's a consumer-initiated transaction is a false or misleading representation under 1692e).

I haven't searched exhaustively for possible causes of action, but I'm not certain that one has a case if it's not a debt collector.

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