Our management team is intent on not doing PSL’s except under the two exceptions noted in the regs. Do we have any Fair Lending issues with limiting these only to RE secured extensions - we don't have a credit card division.

I wouldn't think so since I think it would constitute a "legitimate business reason." My understanding is that most Bank's who plan to continue to do PEL's are taking this route (only secured by RE or open-end) to circumvent the disclosure requirements.

Are we not required to provide these disclosures when the loan is R/E secured?

Correct, not required if secured by real estate or a dwelling. See Reg Z 226.46(b)(5)(iii).