I have a loan officer who does a lot of loans associated with USDA. On occasion she will take an application for USDA and pull a credit bureau to determine what type of program best suits the customer. Often, the info will be sent to USDA and the customer will meet with them before ultimately deciding what course of action to take. I know reg B kicks in when we take the app, but are we safe in not doing TILA and RESPA disclosures at this time, since we don't know what loan product will be used?
Opinions expressed here are mine, not necessarily my employers. This is not legal advice.