The Adverse Action Notice is required for loans. If this isn't a loan or line of credit product, the AAN isn't needed.
The FCRA notice is what you need when a credit report is involved. But the FCRA notice is a consumer reg and not a business.
You may search on "business debit card" to see prior posts. It is important that you and the business understand who has liability for unauthorized transactions.
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AndyZ CRCM
My opinions are not necessarily my employers.
R+R-R=R+R
Rules and Regs minus Relationships equals Resentment and Rebellion. John Maxwell