As Dan indicates, providing the early TIL is the responsibility of the lender. The broker is not the lender. There are some states that prohibit the broker from providing the early TIL. NY may be one of them. I know Mass is.
The question is when does your three business days start running? You cannot be expected to provide the early TIL within three days of the application date if the broker does not provide the appication until four days after taking it. For brokered loans, your time should begin to toll beginning on the date your mortgage dept. receives the application. You need to document that to make sure you are in compliance
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The opinions expressed here are personal and do not represent opinions of my employer.