Adverse action notices under Reg. B apply to credit and the refusal to grant credit. If these do not involve OD lines you should be OK.
FCRA may come into play depending on how you find out about the NSFs. If this is from a CRA such as TeleCheck or Chex Systems you will have a disclosure to make, but it isn't your typical adverse action notice.
Opinions stated are not necessarily that of my employer.
[This message has been edited by Andy Z (edited 02-07-2001).]