Can a loan originator start ordering verifications and requesting documentation from the borrower without documentation of the borrower's intent to proceed? (as a practice our bank does not charge any fees until loan closing)

You can begin order outs as soon as the borrower receives the GFE and indicates their intention to proceed. If it's verbal, the LO should document it in the file. I don't think I would hold up a file just to have the borrower sign an intent to proceed form.

Unless policy says you have too, but that would be a foolish policy in my opinion.