Firm offer of credit

A firm offer of credit is a defined term in the Fair Credit Reporting Act rather than a marketing adjective. Under 15 U.S.C. 1681a(l) it is an offer of credit or insurance that will be honored if the consumer is determined, on information in a consumer report, to meet the specific criteria used to select that consumer for the offer. The statute then closes the list of conditions the offer is still allowed to carry.

Honoring it is the entire test

Selection comes first, against criteria the lender sets. The consumer report is the evidence that the person selected does in fact meet them. If that is how the arrangement works, the offer is firm. Nothing in the definition reaches the rate, the credit line, the length of the letter or the channel it travels on.

The list of permitted conditions is closed

The section allows an offer to be further conditioned on one or more of three things, and then names them. The first is the consumer meeting criteria bearing on credit worthiness drawn from the application, and only where those criteria were established before the consumer was selected and for the purpose of deciding whether to extend credit. The second is verification, either that the consumer continues to meet the selection criteria or that what the application states is accurate. The third is the consumer furnishing collateral, and only collateral that was required before selection and disclosed to the consumer in the offer. That is the whole list. The statute has no general clause for other conditions announced up front, which is the reading most often assumed.

Where the phrase earns its place in the permission to pull

A bureau may furnish a report for a credit transaction the consumer never initiated only if, among the other conditions at 15 U.S.C. 1681b(c)(1)(B), the transaction consists of a firm offer of credit or insurance. Strip the firm offer out and the pull has no permissible purpose left to stand on. The same subsection also limits what comes back: under 1681b(c)(2) the recipient may receive only the consumer's name and address, an identifier that is not unique to the consumer and is used solely to verify identity, and other information that does not identify the consumer's relationship or experience with any particular creditor. How a bureau assembles such a list, and how a consumer gets off it, is in prescreened offer. What the ban effective 4 March 2026 removed for residential mortgage inquiries is in trigger lead.

The duty that attaches once the mail goes out

Section 1681m(d)(1) governs written solicitations by its own terms. Each one carries a clear and conspicuous statement of five things: that information in the consumer's report was used, that the consumer received the offer for satisfying the criteria under which they were selected, that the credit may not be extended if after responding the consumer does not meet those criteria or does not furnish required collateral, that the consumer has a right to prohibit their file being used for transactions they did not initiate, and that the right is exercised by notifying the system established under 1681b(e). The statement includes that system's address and toll-free telephone number, in a format the Bureau establishes by rule.

Three years of paperwork sit behind every offer

Under 1681m(d)(3) whoever makes the offer keeps on file the criteria used to select the consumer, every criterion bearing on credit worthiness that decides whether credit is actually extended, and any collateral requirement, until the end of the three-year period beginning on the date the offer was made. That file is what turns the promise in 1681a(l) from a form of words into something a regulator can test afterwards.

Source: the retention rule is 15 U.S.C. 1681m(d)(3), which runs "until the expiration of the 3-year period beginning on the date on which the offer is made to the consumer", read on 20 September 2026 at govinfo.gov.

What the definition leaves open

No minimum amount, no rate, no term and no expiry are fixed anywhere in it, and no response rate is implied by it. A conversion figure for prescreened credit offers circulates in vendor material; no study or filing standing behind it was found when this page was written, so no version of it appears here and none is derived from anything else on the page. Where the statute stops, this page stops with it.

Source: Fair Credit Reporting Act, read in full on 20 September 2026 in the United States Code at govinfo.gov. The definition, the honoring test and the three permitted further conditions, including the requirement that application criteria be established before selection and that collateral be both required before selection and disclosed in the offer, are 15 U.S.C. 1681a(l). The condition that a non-initiated transaction consist of a firm offer is 1681b(c)(1)(B)(i), and the limit on what a recipient may receive is 1681b(c)(2). The five clear and conspicuous statements, the address and toll-free number, the Bureau's format rule and the three-year file are 1681m(d)(1), (d)(2) and (d)(3). None of these provisions fixes an amount, a rate, a term or an expiry, and 1681m(d) speaks to written solicitations rather than to anything said on a call. Court decisions have read the term further; they were not read line by line for this page, so none is cited and no gloss drawn from them is printed. No response or conversion figure appears above because no study or filing supporting one was found.