Online Out of Area Apps and Adverse Action

Non-real estate loan applicants can use our online form to request a loan. Based on their address we will know if they are in or out of our market area. In some cases an online request is stopped before a credit report is pulled and the person is not allowed to complete the application because they receive a message saying they are outside our market area. The bank does not send any other other notification. Are we required to send an adverse action notice if the bank's practice is to not make these type loans outside of our service area?