Help! We have examiners and they are telling me that I must have proof that the customer received the initial TIL and GFE within 3 business days of receipt of an application. We send out a cover letter with these disclosures that is dated. We have never received any type of acknowledgment back from the customer stating they received the documents within the 3 days.

That's 'cause you don't have to.
The Reg tells you it must be delivered within three days.
You have that proof via the date of your cover letter.

If they want anything more, use the tried and true 'please show me in the Reg where it states we must do that'.
Smile.
Be polite.
Then go sit back and wait for them to move on to the next issue 'cause there's nothing they can come back to you with on this one.

Hang in there.

Your cover letter, which should be dated within 3 business days of the date the application was received, should be all of the proof you need. Do you think they are really referring to notice of intent to proceed?

Niether RESPA nor Reg Z requires such an acknowledgment, or even a signature. Are your procedures, with respect to mailing disclosures, in written form? That usually suffices.

FAQ p10 - 28) should satisfy them on this.

There's no requirement for written or signed proof of intent to proceed either.

Ahou

I am thinking that they are referring to the notice of intent to proceed but I did ask and they said no. We do not collect any fees other than the credit report fee at time of application. Any other fees like the appraisal are collected at closing.