We believe that your organization could use a standing authorization to pull credit reports throughout an employee’s employment at the bank. The FCRA requires that you have the employee’s written authorization to obtain the employee’s credit report after making a “clear and conspicuous disclosure . . . in a document that consists solely of the disclosure” that you may obtain the employee’s credit report for employment purposes. 15 USC 1681b(b)(2)(A). You must provide the required disclosure “before the report is procured.” 15 USC 1681b(b)(2)(A)(i) (emphasis added). An FTC Opinion Letter, Haynes — James (August 5, 1998), has confirmed that you may use a one authorization to pull an employee’s credit reports multiple times: 

We believe, therefore, that a one-time disclosure may be made and permission obtained from applicants and current employees for the employer to obtain consumer reports at any time during the application process or during an employee’s tenure. 

We note, however, that Section 604(b)(2)(A) requires that any disclosure be “clear and conspicuous.” Accordingly, whenever an employer intends for a disclosure and authorization to cover both the application for employment and, if the consumer is hired, any additional consumer reports obtained while the individual is an employee, the disclosure should clearly state this fact.