Procedure for Notice of Adverse Action Forms

A finding in a recent audit may possibly result in a change of procedures for us. I disagree with the finding. Are we indeed required to keep a copy of all Notice of Adverse Action forms when we decline a customer (personal, business) for a checking account? We currently give them a blank form advising them to contact the consumer reporting service (i.e. eFunds) and that is all-we do not even inform them as to why they have been declined. If yes, what information are we required to keep?