Okay - here's something from personal experience, and I will let you folks know what develops.
Two years ago, we bought a house with a purchase money first and second. Both loans were sold on the secondary market. The first payment date was approaching and I did not receive a payment notice from the lender on the 2nd. I pulled out my loan docs and used the "temporary" coupon and mailed the first payment 5 days before the due date.
About 4 days later I receied a notice that the loan had been sold and I was directed to make the payment to the new lender. I called my original lender to confirm this, and was told the loan had been sold. I was also told my payment would be forwarded to the new lender. Then, about 10 days later I received the transfer of servicing notice from the old lender. Interesting conflict was, the old lender showed the transfer date as being effective one month LATER than what the new lender showed.
Long story short - the new lender send me a late notice and their collection department contacted me about the "overdue" payment.
Longer story short - I got the situation straighted out and the new lender reversed the late charge. This after sending copies of EVERYTHING to both lenders via Certified Mail.
Now - I just ordered a copy of my credit report - and lo & behold, the "new" lender shows that I was 30 days late for that payment!
So - since this loan was a purchase money second, does the RESPA rule regarding Transfer of Serving apply? I will be contacting the lender on Tuesday about the situation. But I am not sure I can summon the perils of RESPA here.