After re-reading MLA rules and Q&As, it indicates that the statement of the MAPR and description of the payment obligation is to be provided to the covered borrower orally. This requirement may be satisfied by providing the information to the covered borrower in person or through a toll-free telephone number before the borrower becomes obligated on the transactions or establishes an account.

We don't have a toll-free number for this purpose. Does this mean that in-person is our only option? What about calling the customer directly and providing the disclosure orally before the loan documents are sent via eSign for closing or before a credit card is mailed for use?

I can't see an objection to making the disclosures "in a personal phone call" assimilated to in-person as that will more than meet the results of a toll free call, assuming the borrower isn't paying for the call. My issue with the bank making the calls is time zones as our military customers were in Germany, Korea and the Middle East as well as hours away in the US. When you get 8 or 10 hours difference, you have to time the calls well.