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#188489 - 05/10/04 07:36 PM Servicing Disclosure Transfer Estimates
Anonymous
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If we know that our bank is about to be sold in the next year, should we change our servicing transfer estimates to indicate that our servicing may be sold or transferred to 76 - 100% of the time?

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Lending Compliance
#188490 - 05/10/04 07:54 PM Re: Servicing Disclosure Transfer Estimates
redsfan Offline
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redsfan
Joined: Dec 2000
Posts: 3,455
The Pennant Race
There is an ongoing debate as to whether this disclosure is still necessary. Congress deleted this requirement from the statute in 1996, but HUD has never gotten around to amending Reg X.

Even so, you do not have to change your diclosure for the merger event. The merger does not constitute a transfer of servicing in the meaining of the calculation, because the servicing will be transferred to an "affiliate" (the surviving institution).
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