Our process for opening a deposit account for a new customer includes running a credit report. It’s a soft pull, so it doesn’t pull a credit score and it doesn’t show as an inquiry on the customer’s credit report. Based on the credit report, the customer may be approved for the new account, a debit card and overdraft protection. Or the customer may be denied for any or all products.

Question 1: If the customer is approved for all products, but then withdraws the request for the debit card and/or overdraft protection, do we need to document this withdrawal? If yes, for internal purposes only or should a formal withdrawal notice be given to the customer?

Question 2: If the customer is denied a debit card or overdraft protection, should the ECOA verbiage be included on the Adverse Action Notice? Since the customer hasn’t actually used the overdraft protection or debit card, we’re not sure if this constitutes ‘credit’ at this point.

Thank you!