Preapprovals and Homeownership Counseling List

For a formal preapproval loan program, we're assuming the list does not have to be provided for a preapproval request only. We use the definition of an application under RESPA - which includes a property address - and since the borrower has not identified a property yet we do not have an "application" and thus the list would not have to be provided. We would provide the list when they identify a property and the preapproval requests transitions to a formal application. Does that logic sound reasonable?

That makes sense to me since the list is a RESPA requirement.