Initial notice to customers. can this be given with the application or does it need to be given with the "in-house" loan closing?
I dont see any limitations besides - before any NPPI is shared outside the exceptions - and no later than the time the relationship is established.

So it should be ok to give the notice with the application, mail it before closing, or with earlies?

thanks in advance -- i just have it stuck in my head this needs to be done at loan closing.

We give our notice at closing.

Yes, it can be provided anytime before the loan closes unless you are the broker on the loan...in which case, I believe it is when you are established as the broker.