I want to verify that I am reading this right. If a customer applies for a loan that is a "higher education loan", then they need three disclosures.

1) The solicitation disclosure.
2) The final TIL.
3) The private education loan disclosure.

So my question really is, do they just need a solicitation disclosure and the private education disclosure at close?

(2) Transaction disclosures. (i) The disclosures required under §§226.47(b) and (c) shall be made in writing, in a form that the consumer may keep. The disclosures shall be grouped together, shall be segregated from everything else, and shall not contain any information not directly related to the disclosures required under §§226.47(b) and (c), which include the disclosures required under §226.18.

I am not sure what you mean by "private education loan disclosure". A loan that meets the definition of a private education loan requires an application or solicitation disclosure, an approval disclosure and a final disclosure. Refer to section 226.47. There are model forms in Appendix H (H-18, H-19 and H-20).