We received an app on 12/1 - made the decesion to deny on 12/2, but never sent the denial until now.

That denial notice needs to go out within 3 days to not give the early disclosures - right?

Or is the decesion just enough? I have always operated under the denial notice needs to go, but in reading the commentary id doesn't clearly state that.

Thoughts???

Correct.

If you feel confident in your ability to document verbally communicating with the consumer the denial, that will suffice for timing purposes.