Unable to Make Fresh Start Loan: Action Taken

We currently offer a loan, repayable in six monthly installments at zero percent interest, to help customers bring their checking account to a positive balance. Letters are automatically generated and mailed to customers who may qualify for such loan once their account becomes 30 days overdrawn for $100 or more. Upon receipt of the notification, the customer must call in as directed in the notification (or they can come into the branch) to request the fresh start loan. Their account will be reviewed. If the customer has previously had a fresh start loan with us, we will not make them another fresh start loan. In those situations where a customer requests a fresh start loan and we are unable to make them one, would we owe the customer a Notice of Action Taken? Would Regulation B apply to these fresh start loans?