We are a small servicer. Back in January 2014, we implemented policies and procedures required for Information Requests (1024.36). I'm trying to determine what new servicing rules are effective October 2017 and/or April 2018. In regards to Successors in Interest, we are technically exempt (I think), but I'm confused by the following paragraph in the CFPB Small Entity Compliance Guide:

4.3 Is there a small servicer exemption from the successor in interest requirements?

There is no general exemption from the successor in interest requirements for small services, but small services have the same exemptions with respect to confirmed successors in interest that they have with respect to other borrowers and consumers. For example, small servicers are exempt from 1024.38, which generally requires servicers to adopt servicing policies, procedures, and requirements. However, small servicers are required to respond to certain written requests from potential successors in interest pursuant to 1024.36(i), as there is no small servicer exemption for information requests.

If we have implemented procedures for information requests in 2014, are we good? What more needs to be done?

I found a little bit more clarity the Small Servicers and Key Provisions of the 2016 Mortgage Servicing Rule
https://s3.amazonaws.com/files.consumerf..._Provisions.pdf (2nd paragraph - page 2)

OnTheEdge -

This document was super helpful! The changes for us will be minimal.

Thanks!

Check out the Small Entity Compliance Guide for the new servicing rules. There is a section on what provisions small servicers need to comply with.