Do you consider the printed date on the GFE & early TIL disclosure by the software to be adequate documentation that the disclosures were given within 3 days of receipt of app?

For disclosures that are mailed, we attach a copy of the cover letter (which includes the date and all of the docs enclosed) to the disclosures - haven't had any issues with examiners. Matching up your cover letter dates to the printing date on the disclosures would be a good way to verify that your people are actually meeting the 3 day rule rather than just printing the dislosures and then mailing them at their leisure (not that any loan officer would ever do that )

Thank you. It appears loan officers are the same across the US.

When conducting an audit for compliance with the 3 day rule, I often rely on the date of the cover letter and ensure that the required disclosures are referenced in the letter. But that brings me to the issue of what is considered to be the date of application. FDIC has encouraged the practice of date-stamping the applications with the date of application. Otherwise, reliance has to be on the date the originator signs the application and in the absence of an originator date, the last date the applicant(s) sign the application. We all know how diligent loan officers are when it comes to date of application.

If the lender didn't date the application or there isn't a cover letter in the file, I will also look at dates on other things in the file, especially the credit report. Actually, even if they do date the app I still look at the credit report to make sure they're dating it properly.