If we establish a prepaid card account and the next day close the account because we are unable to verify ID (under CIP); do we need to send an adverse action notice? Reason Other- unable to verify ID.

Our prepaid validation process involves opening the card on day 1, performing validation on day 2, and card file goes into production day 3 (if card is not closed). Any card that fails our validation process is sent a letter indicating why the card will not be opened and provides details on what they can do to provide proper validation to get card opened. * Note, our prepaid cards are not opened in person, but rather through a self registration site that is provided to the employer.