As I am sure you are aware on July 21, 2011 the responsibility for interpreting Regulation X (RESPA) transferred from HUD to the Consumer Financial Protection Bureau(CFPB). So far, the CFPB has not issued any interpretations that change the answer you previously received from HUD.
You may want to consider written procedures that indicate the you REQUEST that the borrower sign the documents at application, but you issue the GFE within three business days of receiving the application, whether the documents are signed or not.