If a financial institution uses ONLY a credit score for approval/denial determination, would debit cards and personal lines of credit (for overdraft protection) be subject to ECOA, FCRA or both?

FCRA applies anytime a consumer report is used to take adverse action.

Both applies to any "credit" product.

Based on Reg B's definition of "credit," I can see where the ODP LOC would be subject to both, but does that definition fit a debit card?

Check the Fair Credit Reporting Act.

If you are pulling a credit bureau to determine if the customer is eligible for a debit card, and it is based on the score, your are required to give the notice on denials.

Our adverse action notices have both.

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FCRA applies anytime a consumer report is used to take adverse action.

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And, my understanding is that (and, please correct me if I'm wrong), that includes taking adverse action on "non-credit" accounts if you use a consumer report (e.g., ChexSystems) to make the decision not to open a consumer checking account or not to issue a debit card in connection with such an account.

I always try to draw a difference between the Adverse Action Notice, prescribed in Reg. B, and the FCRA Notice which often accompanies or is added into the AAN. These are two different disclosures. One addresses denial for a credit product and the other addresses a credit report contributing to the denial of a product or service.

If you tell me you will not cash my check because ChexSystems shows me as a high risk, I get the FCRA Notice. If you deny me a debit card tied to a line of credit, I get an AAN. If the denial is because of ChexSystems or another credit report, I get an FCRA notice too.