We are mailing our "disclosures letter" to customers with the GFE and early TIL. We let them know in the letter that there is no obligation to proceed and if they do decide to proceed, we will need to collect the appraisal fee when they return their VOI, which will in turn signify their "intent to proceed".

In some cases the applicant is dropping their disclosures off the next day or mailing them back right away, and 3 days haven't passed. I know this seems like it should be ok since the applicant has received their disclosures, but since the disclosures were "mailed", are we technically ok accepting the appraisal fee before the three business days is up?

We believe the signed and dated disclosures trigger the date that we can accept the application deposit. If the borrower returns the signed documents while in the 7 days mail waiting period we have been accepting the deposit.

The 3 days are a standard to be used as an "assumption" of receipt for mailed documents. It does not prevent you from accepting mailed disclosures in person before the 3 days passes and collecting your fees. Just be sure your documentation is complete.