I don't believe it's required because of the date of the application. Did you disclose back when you were handling the application that you would provide copies? Or did you then avoid the disclosure by adopting a policy of providing a copy for all loans? If yes to either, spend a buck, make the copy and send it.
I'd do it anyhow. It won't reveal any state secrets, will it?
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John S. Burnett
BankersOnline.com
Fighting for Compliance since 1976
Bankers' Threads User #8