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#2230505 - 02/07/20 05:38 PM Small to Large Servicer - How much time to comply?
BBoyd Offline
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BBoyd
Joined: Mar 2002
Posts: 2,494
MI
I may have missed it in this forum, but once you reach the 5,001 serviced mortgages, and are no longer considered a "Small Servicer" how much time is allowed before you must comply with the servicing requirements for large servicers?

UPDATE: Since I can't remove my post, now that I've found the answer, I'll just provide it for others who may be looking. In the FAQ within the CFPB's Small Entity Compliance Guide it says:

3.2.2 What happens if I no longer qualify for the small servicer exemption? (ยง 1026.41(e)(4)(iii))

The small servicer exemption is determined each calendar year based on the loans you and your affiliates service as of January 1 of that calendar year.

If you cease to qualify for the exemption, you have 6 months or until the next January 1 (whichever is later) to comply with any requirements that you were previously exempt from because you qualified as a small servicer.

The following examples demonstrate when a servicer either is considered, or is no longer considered, a small servicer:

--A servicer that begins servicing more than 5,000 mortgage loans on October 1, and services more than 5,000 mortgage loans as of January 1 of the following year, would no longer be considered a small servicer on April 1 (six months after the previous October) of that following year.

--A servicer that begins servicing more than 5,000 mortgage loans on February 1, and services more than 5,000 mortgage loans as of the following January 1 of the following year, would no longer be considered a small servicer as of that January 1.

--A servicer that begins servicing more than 5,000 mortgage loans on February 1, but services less than 5,000 mortgage loans as of the following January 1, is considered a small servicer for that following year. (Comment 41(e)(4)(iii)-2)


https://files.consumerfinance.gov/f/documents/cfpb_mortserv_guide_v3.2.1.pdf
Last edited by BBoyd; 02/07/20 07:31 PM.
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Mortgage Servicing Rules
#2230588 - 02/07/20 10:48 PM Re: Small to Large Servicer - How much time to comply? BBoyd
Dan Persfull Offline
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Dan Persfull
Joined: Aug 2002
Posts: 47,030
Bloomington, IN
Thank you for sharing what you found.
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#2230595 - 02/08/20 12:23 AM Re: Small to Large Servicer - How much time to comply? Dan Persfull
BBoyd Offline
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BBoyd
Joined: Mar 2002
Posts: 2,494
MI
You're welcome, Dan!
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