Would like to get opinion on whether this scenario is permissible. Hope this makes sense.

If an applicant (phone applicant) is denied credit at the bank could we also run the application through a subsidiary's underwriting engine using the customers credit report information? Could this be done with a documented verbal ok from the customer?

I am familar with FCRA affiliate sharing rules and the requirement to provide opt-out notice and the risk of being deemed a credit reporting agency, but was wondering if we would be allowed to document a verbal opt-in or acknowledgement for sharing the customers credit report with a subsidiary or must this be in writting?