If in our online process we tell consumers that, submission of the credit information is not an application - but merely allows to find out if they qualify and we run credit during the process - does this implicate FCRA/ECOA adverse action notices?

I'm confused. If you are gathering information and obtaining a credit report to determine if they qualify for a particular product, how do you differentiate that from an application?

In our process for offering a product there are other criteria the consumer must meet, so as permitted by Reg B we are permitted to define what we consider an application, however, the problem is 'once' we run credit. What are our obligations relative to FCRA?