Since a denied loan does not meet the definition of "account" the conversation is not relevant. If you obtained information at application, that's fine. If you did not obtain information at application, that is fine, too. Refer to your institution's procedures and make sure you follow them. The final rule requires that we identify beneficial owners at account opening.
_________________________
Sola Gratia, Sola Fides, Sola Scriptura, Solus Christus, Soli Deo Gloria!
www.tcaregs.com