Investors require that we provide the notice of transfer at closing but at closing we do not know when the loan will be purchased so at closing we do not know when the new servicer will begin accepting payments. The notice is required to state the date on which the transferor servicer will cease to accept payments relating to the loan and the date on which the transferee servicer will begin to accept such payments. These dates shall either be the same or consecutive days. I am not sure how to meet the investors requirement and RESPA's.

Which investor? The servicing disclosure statement is all that the investors we work with require to be delivered at closing.

After closing we send the servicing transfer letter and a copy of that is in the file when it goes to the investor. That letter has to be sent within 15 days of the actual transfer.

Because we often do not sell within 15 days of closing, we would be out of compliance if we provided the letter at closing.

I suggest that you contact the investor's compliance department to clarify what they need and when.

TR, I'm not sure I agree with your "within 15 days" analysis. Unless I'm misunderstanding what you are trying to day.

From 1024.21

Time of notice. (i) Except as provided in paragraph (d)(2)(ii) of this section:

(A) The transferor servicer shall deliver the Notice of Transfer to the borrower not less than 15 days before the effective date of the transfer of the servicing of the mortgage servicing loan;

(B) The transferee servicer shall deliver the Notice of Transfer to the borrower not more than 15 days after the effective date of the transfer; and

(C) The transferor and transferee servicers may combine their notices into one notice, which shall be delivered to the borrower not less than 15 days before the effective date of the transfer of the servicing of the mortgage servicing loan.