In 24 CFR 3500.7(a)(1) and 12 CFR 1024.7(a)(1), it states that the lender is not required to provide the applicant with a GFE if, before the end of the 3-business-day period: (i) The lender denies the application; or (ii) the applicant withdraws the application.

What if the decision was approved not accepted before the end of the third business day, are GFE disclosures required?

My question is, how would the customer know the approval conditions to then not accept them without being issued a GFE?

I have to agree with "RulesFollower." If the potential borrower did not withdraw the application - then a GFE needs to be issued. Then you have complied with the requirement.

My thoughts are along the same lines as RulesFollower's.
A quick denial is done on the basis of the CBR and information on the application.
You're not supposed to ask for any more documentation till after the borrower gives intent to proceed after receiving the GFE.

So the answer to your question is yes, GFEs are required.
Moreover, I'd be looking at the procedure that allowed an approved by not accepted to occur like this.

I think this is a big red flag to an examiner to dig into the process. Application, GFE, Intent to Proceed, Other information, approval/denial.

How would you have obtained intent to proceed without a GFE?

Not a good idea. If your customer came in and said I have shopped I know I want to go ahead with your bank, that would trigger a GFE. You can't go forward without it.

One other thought...if the customer accepted, what fees would you use on the comparison chart of the HUD-1? You would have to enter 0 as you did not disclose.

You need a GFE.