Question regarding denying request for ACH piece of our Cash Management program...if our requests are going through our Commercial Lenders for approval/denial and a request is denied. Do we have to comply with Reg B Adverse Action requirements? I know if a credit bureau is pulled we have to address FCRA - but do we have to disclose the full-blown Reg B disclosures (reasons for denial) or is this not considered a "lending product" sunject to Reg B requirements - there is no note, etc. Curious how other institutions handle this, as this is a new area for us. Thanks!