When opening account online if the account is not automatically accepted the screen states "Your account is currently pending review, we will reach out to you within 1 business day with more information". Can we include something such as "Your account is currently pending review, possible reasons for this review could include but are not limited to mismatched address, date of birth or tax identification number, we will reach out to you within 1 business day with more information."

From an adverse action standpoint can we include just those examples, what if the real reason for the review is possible fraud, account abuse, IP address velocity or mismatched phone number?

If the account is denied an adverse action would be sent.

If this is a deposit account, Regulation B adverse action notices don't apply. You are only required to send an FCRA adverse action notice if you are denying an account based on information contained in a consumer report (e.g. credit report/ Chexsystems.)

If you're just not opening account because you require additional information that you haven't received, there is no requirement to send an adverse action notice with specific reasons.

Thank you, If we wanted to include those as possible reasons for the 1-day review, would that raise any compliance flags then?