For the CHARM and HELOC brochure, are these required when only scenarios are provided to the consumer (in person)? I understand that the regulation notes "at the time an application is provided to the consumer," however, I read in an older post that if a consumer shows interest (not that an application was provided), then the brochure(s) should be provided to them at that time (if in person) because they are considered shopping disclosures. I wanted to confirm as I was confused on the last part.

Thank you!

They are required at application. Can you give them at other times - sure. That is up to you, but why not?

Thank you!