Pulling Credit on Application and Subject Property

My Compliance Officer says that my bank cannot pull credit on an applicant who wants to get pre-approved until the applicant finds a house. She says that RESPA states that the subject property address is required in order to have a complete application. I have always been under the impression that TBD was okay to use as the subject property. Do you agree with her or should I be okay to pull the credit on this applicant and provide a Pre-Approval letter?