For all of you small servicers out there - How will you handle an oral request indicating a person may be a successor in interest? Will you respond orally and work everything out that way or will you still send the written notices?

The CFPB's Small Entity Compliance Guide seems to skirt the issue and refers back to what you need to do if you don't meet the small servicer exemption.

Technically, from a Regulatory standpoint, a Small Servicer is not required to do anything in this situation, which is why the Small Entity Guide "skirts the issue" as you say. When it comes to potential SII's, Small Servicers are only required to respond to actual written requests for information that contain (1) the name of the borrower from whom they received an ownership interest; (2) information that enables the service to identify the loan accounts, and (3) a request for information.

However, from a "customer service" relations standpoint, it may be a good practice here to provide the caller with a written description of the documents required to confirm SII status, as well as how (and where) to submit a written request for information under 1024.36(i).

Thanks for the insight JPC, I appreciate it!