You could be a landlord if you hold any rental property in REO.
Reg X amendments are effective 8/31/21 (not 8/13). While they don't directly affect small servicers, they and the Bureau, with its heavy public relations reach to consumers, set borrower expectations. If you have a lot of loans in some form of forbearance, you better be ready for the tsunami of consumer inquiries as the forbearance agreements approach their end dates.
You have the Reg F amendments right.
John S. Burnett
Fighting for Compliance since 1976
Bankers' Threads User #8