A CRMLA servicer will transfer servicing on 1 October and plans to notify borrowers on 24 September. Assuming the ordinary Regulation X transfer-notice rule applies and no exception is available, is the transferor’s proposed notice timely?
Correct Answer
B) Too late: the transferor notice is due at least 15 days before the date
A CRMLA licensee servicing federally related mortgage loans is bound by Regulation X, under which the transferor notifies not less than 15 days before the effective date. Other choices: 7 days and 45 days are not the period; and a state license adds obligations rather than displacing the federal ones. Source: 12 CFR 1024.33(b)(3); Cal. Fin. Code § 50000 et seq.
Why This Is the Correct Answer
A CRMLA licensee servicing federally related mortgage loans is bound by Regulation X, under which the transferor notifies not less than 15 days before the effective date. Other choices: 7 days and 45 days are not the period; and a state license adds obligations rather than displacing the federal ones. Source: 12 CFR 1024.33(b)(3); Cal. Fin. Code § 50000 et seq.
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