Yes, the applicant is required to provide his or her AGI from the tax year of their choice. However, given the fact that the information is being provided to the Internal Revenue Service, that could hardly be classified as a disclosure. Logical parallels would be a refusal to provide a Social Security Number to the Social Security Administration or balking at providing a driver's license number to the bureau of motor vehicles.
The IRS already has the information. They are using it to verify the identity of the individual who is purporting to act on behalf of the bank.
The system's primary purpose is to help financial institutions clean up their information reporting.
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In this world you must be oh so smart or oh so pleasant. Well, for years I was smart. I recommend pleasant.