This scenario was just posed to me and I really need some help. Our new sales coordinator wants the lenders to pre-approve customers for a credit card when they do say a mortgage with our bank. Instead of sending the customer a pre-approval letter in the mail he wants our new accounts people to personally call them to let them know they have been pre-approved. Then for even further convenience he wants the customer's activation of the card to be their acceptance of the card. He is saying that it is not necessary for them to sign anywhere that they are accepting the card. Is this true? Where does it say that they do not have to give their signature accepting the credit card?

How are they pre-approving the credit card? If it involves the use the borrower's credit report - it is not a permissible purpose under FCRA.

Regardless, you are going to want to review all the rules for issuance of a credit card under 226.12 and the commentary.

Regarding the signature issue, that is a question for your attorney.

I think they are pre-approving the credit card based on the information the customer provides when they do their mortgage or other loan through our Bank. That was my understanding.