Are HELOCs exempt from Respa's § 1024.39 Early intervention requirements for certain borrowers. Specifically the 45-day written notice? I have reviewed all of Respa's citation addressing (coverage) and (Exemptions) including a list of the partial exemptions for HELOCs but as of now, I cannot find a direct exemption from the requirements in 1024.39. Does someone have a citation that clarified if HELOCs are exempt from requirement to make contact by day 36 and send written notice by day 45?

Not so much exempted as not covered. Only mortgage loans are covered by the servicing provisions of RESPA.

1024.31 "Mortgage loan means any federally related mortgage loan, as that term is defined in § 1024.2 subject to the exemptions in § 1024.5(b), but does not include open-end lines of credit (home equity plans)."

Thank you so much!