I don't know why you would be embarrassed. What with all of the changes to various regs and slightly different definitions for applications in several of them, confusion is natural.
The key under RESPA is getting the customer's financial information "in anticipation" of a credit decision, and this to me is triggered not by the customer asking for a quote, or a question about a particular property, but going through your application processe and giving info like their current income/salary, bank accts, etc. This could be written or oral, and if a loan officer has a written application on file from a previous transaction that they then pull and update or confirm over the phone while giving a quote, that to me triggers the early disclosures.
The definition is below.
For early disclosures under RESPA (HUD X) this is the definition:
Application means the submission of a borrower's financial
information in anticipation of a credit decision, whether written or computer-generated, relating to a federally related mortgage loan. If the submission does not state or identify a specific property, the submission is an application for a pre-qualification and not an application for a federally related mortgage loan under this part. The
subsequent addition of an identified property to the submission converts the submission to an application for a federally related mortgage loan.