We have a property in which both borrowers are now deceased. The loan is currently 85 days past due. Do we still need to wait the 120 days to start the foreclosure?
I found a letter dated October 2013 issued by the CFPB that talked about trying to eliminate banks foreclosing on so many properties after the borrowers are deceased and wanting the banks to work with the successors more.
My thought is that we should still wait the 120 days to give the successor the same rights as the borrower had.
Anyone have any thoughts on this?

I think that's a good idea, given the focus on successors in interest. I'd suggest that if you can identify the personal representative of the estate of the last of the borrowers to die, you should attempt contact. Ditto any known family members. You want them to be reminded there's a mortgage obligation that needs to be addressed, and also to learn whether there's anything already underway that might affect your need to foreclose at some point.