If we purchase another bank (it is merged with us), do we need to send out mortgage servicing disclosures to all customers with 1-4 family residential loans of the purchased bank?

If so, and we miss the 30 day timeframe, what are the reprocussions? I heard that one is that we would have to refund any late fees paid by any of the affected customers since the date of the merger.

You should look at 3500.21(d). If you do not meet the exception, a transfer of servicing notice would be required. I don't know what the penalty for non-compliance is, but it would make sense that you could not charge a late fee if you changed where payements are to be sent, but did not tell the customer.

The address to send the payments did not change. The only change was the payee on the check (Was 'ABC Bank" - IS NOW 'XYZ Bank'.

Hard to understand WHY we need to send out the servicing disclosure.....

How could the address not change?