That section of RESPA is governed under the following:
1024.30—Scope.
(a) In general. Except as provided in paragraphs (b) and (c) of this section, this subpart applies to any mortgage loan, as that term is defined in § 1024.31.
1024.31 - Definitions
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).
Also, even if it was covered, since the loan is not yet delinguent, you can pretty much do what you want to.
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