If a customer (with an existing DDA) applies for a debit card and is declined on the basis of information that the bank already has (ex. they are a repeat overdrafter) would a notice of adverse action be required? No CRA data is being used (or even pulled) in the decision, just internal bank records.

Thanks for any help!

No adverse action notice would be required.

Thank you much!

Would it not be required because the debit card is not a "credit" product, or because no outside information was used for the decision? I'm not sure from the response.

Also (long hypothetical coming), if the account does not have an overdraft feature, but adding the debit card would add that feature, and the customer was being denied a debit card because they did not qualify to be able to have overdrafts, would that constitute adverse action?

A FCRA adverse action notice is only required if the information from a credit report contributed to the denial. It would be the same in your hypothetical example.

The fact that you pulled a credit report is not a determining factor, as long as the information in the report was not used. For example, if you denied a loan due to collateral values, a FCRA adverse action notice would not be required even if you also pulled a credit report, as long as it had no bearing on your decision.