Answer:
Technically, the SFHDF does not have a timing requirement. However, if the property is in a SFHA, the notice must be delivered a reasonable period of time before closing the loan. Therefore, you back into the logic that the SFHDF should be done so you have sufficient time to deliver the notice in the correct time. If the property is not in a SFHA, you could argue that you don't need to complete the SFHDF until the day of closing (but you may very well have an argument on your hands with an examiner).
First published on BankersOnline.com 6/01/09
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