When we have a pre-approval and there is no property listed; we do not send out a GFE & early TIL. Do we still have to send out the new Servicing Disclosure Statement?

No.

§ 3500.21 Mortgage Servicing Transfers.
* * * * *
(b) Servicing Disclosure Statement; Requirements.

(1) At the time an application for a mortgage servicing
loan is submitted,.........

You do not have an application under RESPA without a property address:

§ 3500.2 Definitions.

Application means the submission of a borrower’s financial information in anticipation of a credit decision relating to a federally related mortgage loan, which shall include the borrower’s name, the borrower’s monthly income, the borrower’s social security number to obtain a credit report, the property address,............