Reg DD requires that account disclosures be provided to consumers upon request and upon account opening. What is considered upon account opening?

We have CSRs that solicite new accounts on the road. They hand out fliers and verbally explain features of the various accounts offered.The "potential" new customer signs a New Account Card, providing all the required CIP information. The CSR documents the individuals ID and accepts an inital deposit required to open the account. Only when the CSR returns to the branch to have someone upload the new account information and post the deposit is the account officially opened. Since the new customer did not come into the branch, is this the same as the customer not present, therefore, the disclosures can be mailed to them within 10 business days or earlier?

I'm also concerned with the CSR holding the customer's initial deposit over night (or over the weekend) before returning to the branch. How are others handling this process to solicite and open new accounts outside of the branch?

This is a mobile branch and must be liscensed. Are you authorized to operate a mobile branch?

Here's one prior thread

Here's another