I seem to remember the CFPB clarifying what constituted being "120 days past due" back in the Fall. I cannot seem to find the citation now. Was it a loan 120 days late based on the due date? or was it a loan that had been consistently past due for 120 consecutive days (i.e. loan due for 9-30-16 on 11-30-16 BUT the loan hadn't been current with all interest and princ 7-30-16)?
Any citation would be appreciated.