The notification requirement under Reg Z that must be sent within 30 days to the borrower when their mortgage has been sold or transferred, is the mandatory compliance date January 1, 2011?

Also, does the "covered person" who purchases the mortgage have to actually provide the notice, or can their servicing agent send it on their behalf as part of their servicing agreement? I cannot find anything in the final rule that would prohibit this from being handled by a creditor"s contracted servicing agent, as long as all of the required information is accurately provided to the borrower.

Compliance is required as of 1/1/11.

The non-owner servicer does not meet the definition of a covered person therefore IMO they cannot send the notice on behalf of the purchaser (covered person).