You appear to be correct. The transferor must send its transfer notice at least 15 days before the effective date of the transfer and the transferee must send its notice no more than 15 days after the effective date. But you have the option of giving a combined notice. If you do, that notice must be given at loan closing. There are a few permissable circumstances that allow you to give this notice after the effective date of the transfer but it is for unusual things like the servicer has begun bankruptch, the FDIC or some reg. agency has some proceedings, going on, but in most cases you have to follow the rules for the 2 notices or the 1 notice.