The bank is in the process of implementing a program for consumers to open accounts online. In the event the consumer is not able to answer personal questions correctly based on information the software pulls (i.e. "out of the following states, where have you lived"), the account would be denied an email provided to them. Will the bank still be required to provide an AAN since we are not using a scoring system to make that decision?

If you aren't using a consumer report, then an AAN under FCRA would not be required.

Where is the information being pulled from?