There is no mention of a loan in the adverse action notice requirements in Sec 615 of the FCRA:
Sec. 615. Requirements on users of consumer reports
(a) Duties of users taking adverse actions on the basis of information contained in consumer reports. If any person takes any adverse action with respect to any consumer that is based in whole or in part on any information contained in a consumer report, the person shall...
So you are selling your payroll card product to employers and then you are going to deny individual employees a card? If I was the business I would leave. These are preloaded cards, are they not.
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