I don't believe most banks require an application. We didn't. Regardless, it depends on what you do with the application. If it contains critical disclosures, they must still be given. The trick though, is to give a card that is not active. If you mail it to a customer they then have to call or otherwise contact you and answer certain questions to prove they are in fact the customer and they are calling because they received the new card. Then you activate it. They then, have the liabilities imposed under your agreement with them.
My opinions are not necessarily my employers.
Rules and Regs minus Relationships equals Resentment and Rebellion. John Maxwell