We are a small servicer, only servicing our own loans. Not small enough to be exempt, but still comparatively small. We have workout/forebearance processes to help our borrowers catch up. We have not used formal modification agreements or participated in any of the government's HAMP or modification programs. This new rule does not require that we provide formal modification programs, does it? Do we have to take a formal application for a workout agreement? The rule uses language such as they should be told of their options, but it really doesn't define what options are required or must be made available, does it?

It appears it does not require you to have any more than what you have, if anything.