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#2173829 - 04/17/18 04:47 PM Periodic Statements - Small Servicers
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As we are all likely aware, the provisions of 12 CFR 1026.41 do not apply to "Small Servicers." This being the case, is there anything that stipulates how a Small Servicer provides periodic statements? Could a Small Servicer go so far, from a Regulatory standpoint, as to not even provide periodic statements?

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#2173831 - 04/17/18 04:56 PM Re: Periodic Statements - Small Servicers Compliance NABW
rlcarey Online
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rlcarey
Joined: Jul 2001
Posts: 83,227
Galveston, TX
If you are exempt from 1026.41, you can do whatever you want to. There are no other requirements.
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#2173837 - 04/17/18 05:11 PM Re: Periodic Statements - Small Servicers Compliance NABW
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That's what I thought, just wanted to put it out there in plain English. Would it just be governed by a contract agreement, if applicable?
Last edited by JPC; 04/17/18 05:12 PM.
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#2174036 - 04/18/18 03:34 PM Re: Periodic Statements - Small Servicers Compliance NABW
John Burnett Offline
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John Burnett
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Cape Cod
Yes. If you agree contractually to provide a periodic statement or coupon book, you ca be held to that. In that case, anything you issue would at least have to be be accurate and not deceptive.
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