You remember correctly. If you use the exceptions to the risk based pricing requirement, an exception notice must be provided to all consumers (individuals who request credit), regardless if the loan is consummated. 1022.74(d)(1)(i), (e)(1)(i) and (f)(1)(i) is where you’ll find language that states:
(1) In general. A person is not required to provide a risk-based pricing notice to a consumer under §1022.72(a) or (c) if:
(i) The consumer requests from the person an extension of credit…and
(ii) The person provides to each consumer described in paragraph (d)(1)(i) of this section a notice
There are three model exception forms (H-3, H-4, H-5). You’ll need to use the one that best suits the credit request.