It is common now for banks to offer the ability to view a free credit score and I assume the written instruction permissible purpose is relied on. Does FCRA allow for the written instruction to cover endless pulls for this purpose?

I believe they are tying it to the review purpose and you only see this when you are talking credit cards or open-end credit.

That is what initially thought but I have seen many banks offer it within the online banking platform even when they only have a checking account.

I do not know then. Of course, banks have been know to violate the FCRA on occasion. You would have to go through the process and try and determine how permissible purpose enters into the picture. The only service that I have that does that are ones tied to a credit card.

Are you talking about services that allow customers to track their own credit score? I assume those are based on written permission as well, and I don't see why it would run afoul of FCRA. I'm not sure if or how an institution would use the credit score themselves. If they are, then there might be some issues, but if just to provide to the customer, I don't see the issue.

It appears that is what they do. Here is part of Credit Sesame's contract:

If you choose to register as a Member, you must at the time of signing up provide “Written Instructions” to authorize Credit Sesame to access your credit report. The terms you must agree to in order to provide such authorization will be displayed to you prior to you agreeing to participate in the Member program. You may withdraw your authorization and membership at any time in the manner specified in this Agreement.

Can written authorization be this broad? I thought written instructions for permissible purposes had to be specific?

That is the $64,000 question. Since this is a relatively new phenomenon, I am not sure that there has been any comment on it by either the FTC or the CFPB.

I see a lot that are using it to provide personalized credit offers I assume the written authorization would need to include reference to this usage correct?