Just read the CFPBs FAQs released and #2 is frightening.

They tell us we have to send Periodic Statements for Mortgages, however they do not give us safe harbor when using their forms.

Now the dilemma is do we send the statements and risk bankruptcy penalties, or do we not send them and risk of violating regulation?

What are others discussing?

How could the CFPB provide a safe harbor for a bankruptcy law violation? They've produced samples and regulations that they believe allow servicers to not violate an automatic stay, but ultimately the CFPB has no jurisdiction over bankruptcy proceedings and law. They have never offered any kind of safe harbor for using their periodic statement formats, I'm really not seeing what is so frightening from this, but maybe I'm missing your point?

There is an exemption from the statement requirement under certain circumstances (1026.41(e)(5)) unless you've received a reaffirmation or consumer request for statements or a coupon book.