Our bank just got sold, the new bank, as the transferee will be sending the notices, does my bank, as the transferor also needs to send a separate notice? Thanks.

A follow-up question - Do the RESPA servicing transfer rules cover HELOCs? thank you

The transferor and transferee servicers may provide a single notice, in which case the notice shall be provided not less than 15 days before the effective date of the transfer of the servicing of the mortgage loan.

No to HELOCs

Great, thank you

Just happened here and for whatever reason, we sent separate. Ours, as the acquired bank , went out pre-sale and their's went out post.

Had it been my decision, I would have combined both entities for the RESPA notice pre-acquisition and the Reg Z notice post by the surviving entity.

I think I'm losing it or have been working M & A stuff for too long today. Does the RESPA Servicing notice (under 1024.33) go out around the legal close of the sale (combined notice to 15 days prior to the sale close) or 15 days prior to conversion. I think it's 15 days prior to legal close since the old bank will cease to be the legal servicer, but I get confused on the address for payments - I think we would use the address of where payments are sent now to the old bank.

Also, under Reg Z 1026.39 - similar disclosures are required, except the loans covered extend to certain HELOC's. Are these due within 30 days following the date of the transfer - again is this 30 days from legal close or conversion. I think legal close. I think in the past, I've seen the RESPA and Reg Z content combined into one notice and provided to the larger population of loans (i.e. provide combined notice to mortgage loans required under RESPA (dirt loans) even though they don't technically need to be provided all of the info that reg Z requires for some closed-end and open-end loans, like mobile home loans (dwellings but no dirt).

Not sure if I'm making sense.

These are two totally separate requirements.

The notice of the transfer of servicing has to go out at least 15 day prior to transfer. So, fifteen days prior to when you expect customers to send payments to the new location or contact a new location for information.

The notice of the transfer of the mortgage, whether servicing is being transferred or not, has to go out no later than 30 days after the date of transfer. This would be when the loan was purchased or the acquisition/merger was final.

Thanks Randy.

Yes, I know they are two separate and based on timing, they couldn't go together even if they could.

Just so I understand, RESPA Servicing goes (according to time requirements and combined or separate notices) at least 15 days before the mortgage consumer should send payments elsewhere (although we will still accept at the branch). I understand this to mean it should be sent as part of the conversion process as during the "interim" period between legal close / final sale and conversion, payments are to be made as usual to the branch office(s) of the acquired bank - even thought those loans are technically now loans owned by our bank. I'm probably thinking about this too hard. For example, if the conversion is 2/15/2022, a combined transfer notice would need to go out at least 15 days before 2/15/2022.

Whereas, under the Reg Z servicing disclosure requirement, we as the purchasing bank, send notice to the required mortgage customers no later than 30 days after purchase was final (so what we call the closing date). For example, if the legal close / purchase was made final on 11/1/2021, this notice would need to go out within 30 days of 11/1/2021.

Correct. However, you said "under the Reg Z servicing disclosure requirement". You need to get servicing out of that sentence. The Regulation Z notice is the transfer of the mortgage and has nothing to do with the servicing of the loan.

Noted Randy! THANK YOU! You've made this much more clear to me and I appreciate your time and effort!