Account Declined - Adverse Action Notice

Before we open a new account, we use a service provider that checks to see if the potential customer has any closed for cause accounts from other institutions and vendors with outstanding balances. If we decline to open a transaction (checking) account based on this information, do we need to give an FCRA adverse action notice? We do not offer an overdraft protection program, but we do pay some customers into overdraft and charge them an overdraft fee per item.