Your early disclosures for TIL and RESPA are not required because it makes no sense to make loan disclosures when you know the loan is being denied. 226.19(a)(1) 4
, which is in the Official Staff Commentary explains this. Remember, the OSC has the same force and effect as the regulation itself.
My opinions are not necessarily my employers.
Rules and Regs minus Relationships equals Resentment and Rebellion. John Maxwell