Just went to the federal register and there are three different disclosures. A solicitation, an approval and a final disclosure. Why is there an approval disclosure? This does not make any sense.

OK this is crazy

(2) Approval disclosures. The creditor shall provide the disclosures required by §226.47(b) before consummation on or with any notice of approval provided to the consumer. If the creditor mails notice of approval, the disclosures must be mailed with the notice. If the creditor communicates notice of approval by telephone, the creditor must mail the disclosures within three business days of providing the notice of approval. If the creditor communicates notice of approval electronically, the creditor may provide the disclosures in electronic form in accordance with §226.46(d)(3); otherwise the creditor must mail the disclosures within three business days of communicating the notice of approval. If the creditor communicates approval in person, the creditor must provide the disclosures to the consumer at that time.

The way I read this is we NEED to give three disclosures now. Application, approval and loan. Regardless of if we make the decision and loan on the same day.

Yep!