Potential customer wants to open a Rewards Checking. Credit is pulled to determine whether the consumer is qualified for that account. Based on info in the Credit Report, they are not. We offer instead a second chance checking account (which requires a perpetually held balance in a savings account).

1) The customer accepts the second chance checking, but neither a combined counteroffer/adverse action notice nor a FCRA AAN is provided to the member.
- - I don't see how we can get out of sending a FCRA AAN since we didn't provide a combined notice.

2) The customer rejects the second chance checking and the FI provides a written FCRA AAN.

Can anyone speak to #1 scenario and whether we should be providing either a written combined notice or written FCRA AAN for deposit accounts?

There is no counter-offer exemption in the FCRA - you owe them the notice regardless. You are mixing in Reg B, which does not apply to deposit accounts.

Thank you for confirming that it is required; that is what I understood to be needed.

A related question about an AAN on a deposit account. I know Reg B has the 30-day timeframe to issue an AAN. Is there a timeframe under FCRA for issuing an AAN when a deposit account is denied?

Section 609(a) of the FCRA does not include a timing requirement. I recommend that the notice be given promptly, within a day or two, or you can completely lose control over the process.