Much depends upon your agreement with the broker.
The problem is - there are NO written agreements with the brokers (which will likely change, but for now - no agreements.
Explain this one:
Revised GFE (if necessary after receipt of initial GFE from broker and valid COC)
Why would the broker be exempt from delivering the early TIL, early ARM and Charm booklet if you didn't get the application within three days of application? If you are getting the application that fast, then why would they issue the GFE only???
The application is not usually received by the bank until after the 3 days has already passed. In reading TILA, the early TIL disclosure must be provided by the creditor. Since the broker is not the creditor in the transaction, there is confusion.
It sounds like you are saying that since we do not get the application that quickly, then all early RESPA/TILA disclosures should be provided by the broker. Correct?
Then, the bank would issue a revised GFE if a COC occurs and one is required.