Hard inquiries appear on your credit report every time a lender pulls your credit for a loan or card application. Each one can drop your score 3-5 points and stays for 2 years. But here's the thing: not all inquiries are authorized. I'm Rick Jefferson, and I regularly remove unauthorized hard pulls from ITIN credit files using FCRA §604.
Authorized vs. Unauthorized Inquiries
Under FCRA §604 (15 U.S.C. § 1681b), a hard inquiry is only legitimate if the entity had a "permissible purpose" — meaning you applied for credit, insurance, or employment, or an existing creditor reviewed your account. If a company pulled your ITIN credit file without your knowledge or consent, that inquiry is unauthorized and removable.
How to Identify Unauthorized Inquiries
- ✓Review the inquiry section of all three bureau reports
- ✓Make a list of every inquiry — company name and date
- ✓Cross-reference with your actual applications
- ✓If you didn’t apply to that company — it’s likely unauthorized
- ✓Check for dealer inquiries (auto dealers often submit to 5-10 lenders from one visit)
The Dispute Process
For unauthorized inquiries, we file a §604 permissible purpose challenge directly with the bureau. The letter states that the inquiry was made without your consent, cites the specific section of the FCRA, and demands removal. The bureau must then contact the inquirer to verify permissible purpose. If they can't — the inquiry gets deleted.
For rate-shopping inquiries (mortgage, auto, student loan), the scoring model groups multiple inquiries within a 14-45 day window as a single inquiry. If your report shows them as separate hits, that can be corrected.
How Many Inquiries Is Too Many?
1-2 inquiries in the past 12 months is considered normal. 3-5 starts to raise flags. 6+ can significantly impact your score and signal risk to lenders. If you have excessive unauthorized inquiries, removing them can provide a quick 10-25 point score boost.