We have a few customers who are using their ATM cards when our system is offline and getting funds that are not in their accounts. This is causing the account to be overdrawn. The same individuals keep doing this. We would like to block their access to ANY funds when the ATM system is offline. Can we do this? If we can, what do we need to do to make sure we are in compliance? I'm assuming we can send an adverse action notice stating what we have done and our reasons for doing so, but I can't find anything that deals with this situation.