I see this a lot to Kathy, but I want to clarify that "at closing" is not what Reg B requires. The preamble (section by section analysis) to these requirements indicated this had to be done at the time of the initial application. The FRB felt there was too much duress at closing to ask this then. It is true that most people will sign just about anything at closing. The logical time to ask people "who is applying" is at the time of application.
That said, if a LO gets the documentation at closing, I believe this is not sufficient. They must get it when taking the telephone application. If they want to follow up with a "are you sure" at closing, that is fine, but it must be in addition to the earlier documentation.