I have a consumer home equity application that was taken and the loan officer verbally contacted the customer and indicated they were being denied same day application was taken. No early TinL disclosures were done b/c loan was denied. The adverse action was completed 4 days later b/c of second review process. Is it ok that earlies weren't provided the officer comments indicate they spoke with the borrower and verbally told them denial, but since AA is dated 4 days after application is that a problem with no earlies?

Why wouldn't you date the AAN the same day the LO contacted the customer?

As long as the denial is properly documented there is no problem.