Previously identified SII have to be reconfirmed?

Do the Successor in Interest rules that went into effect 4/19/18 have to be applied to existing loans with a successor in interest were we had followed 1024.38(b)(1)(vi)--(Upon notification of the death of a borrower, promptly identify and facilitate communication with the successor in interest of the deceased borrower with respect to the property secured by the deceased borrower's mortgage loan.) and we had procedures in place for confirming their ownership interest in the property.

For example a loan we have the mom passed away, son became the point of contact and is making the loan payments. Do we need to confirm him under the new rules for him to be a confirmed successor in interest and receive all of the benefits listed in 1024.30(d)?

Sorry if this has been answered. I searched previous threads and did a quick look at the Federal Register but did not find my answer.

Well, allowing something to continue for years that should have been addressed at the time years ago (regulations or not), do not really fit into a nice little box. I would be approaching the borrower and working with them to get this structured correctly and the property transferred and hope that there are not other probate issues or competing interests that will cloud the title hanging out there.