I am confusing myself and need some direction - we qualify as a small servicer but we still must comply with section 1024.33(b) - notices of transfer of loan servicing - right? If we fail to provide this notice in a timely manner (1024.33(b)(3)) or fail to provide all the contents (1024.33(b)(4)) we have regulatory violations don't we? I don't see that small servicers are exempt from this particular part of the regulation.

You're correct. There is no exemption.