Someone acting on reliance of the information you provide could face extreme adverse consequences, and disclaimers will not always protect you.DISCLAIMER: None of the above shall be taken as comprehensive analysis of the law in any one particular state.

Assuming your information is complete, it appears to me that adverse circumstances befell both  parties. 

If you get in front of a Judge or Jury, and either of them do not like you, the questions alone could allow for an adverse, non-appealable ruling.

If they weren't denied based on credit, then no....The FCRA does not limit adverse action letters to credit - it requires adverse action letters whenever an adverse decision was based on information obtained from a third party reporting service.

That said, I did call HomeForward yesterday to see if it would be possible to put these tenants on Section 8, and that way, if I raised rents to market, it would not adversely affect them.  

You can do the grind for a few years as the operator but over time it will wear you down and have adverse effects on quality of life.

“HUD will use the full force of the law to protect the fair housing rights of folks who’ve been arrested or who’re returning to their communities after serving time in jail or prison,” HUD Secretary Julian Castro warned.By “full force,” he means the “disparate impact” theory of civil-rights enforcement, which HUD claims is written into the Fair Housing Act even though the phrase appears nowhere in the statute.Disparate impact holds businesses liable for colorblind policies and practices that may have adverse outcomes for minorities — in this case, screening all apartment applicants for criminal histories.

Adversely if they do not meet these targets the agreement is voided and you are able to pursue other managment. 

If nothing else, you will have a judgement that can be noted on their credit history.Something you might consider for the future: in the form we use to gain consent from an applicant to pull their credit history there is wording which also gathers their consent to report payment events (both adverse and positive) to the credit agency (this wording comes from the agency itself and is part of a template we are to use as part of the service).  

Also be wary of wholesale and fix and flips that may have adverse tax consequences and need to be insulated in their own separate tax person (corporation) to avoid propagating to your other passive activities.