RESPA - Compliance Vs Lender

Requirement to send GFE and ETIL upon application when property is identified; lenders think that property is not identified until there is an accepted offer to purchase, i.e. contract. Compliance feels that when the applicant finds a property that they want to negotiate for, that is the trigger for the disclosures, and the lender should be in contact with the applicant to get the property address. RESPA doesn't define what constitutes the identification of the property. Who is correct, Compliance or Lender?