I would probably not recommend that the 12 day 50(a)(6) notice be delivered on loans where it is not applicable. There is no timing requirement on the 12 day disclosure other than allowing 12 days to pass after delivery to close.
That is a different situation than when a borrower requests a rate/term refinance of an existing 50(a)(6) loan, which requires a different 12 day disclosure that must be delivered within three days of application. However, it the lender later finds out that is the actual request, the lender can have the applicant modify their application to state their intent and you have three business days from that point to deliver the disclosure.
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