Not to speak for Randy, but yes you need to provide an adverse action notice because you are denying them an account.
A seperate issue is the notice of negative information. This notice is not required as in this case YOU are not reporting information. Even if you were reporting info to Chex Systems you would not need the notice of negative information as it is not a NCRA.
Notice of negative information is only required if you are going to, or have, reported negative info to a NCRA.
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Then again I may be totally wrong