SAFE MLO test · Most missed · Episode 8

Who Owns My Loan?

2:04

The transcript is below. The full episode plays in the EstatePass MLO dashboard.

Chapters

0:00The question
0:33Three clocks
1:00Count it
1:12The answers
1:47Recap

In short

Under Regulation X a servicer acknowledges a written error notice or information request within 5 business days and answers most information requests within 30, which it may extend by 15. A request for the identity and contact details of the loan's owner has its own clock: 10 business days, with no extension. A letter received on Thursday, June 4 must be answered by Thursday, June 18.

5 business days: acknowledge an error notice or information request.
10 business days: who owns the loan, and how to reach them. No extension.
30 business days: most other information requests, extendable by 15.

Transcript

0:00The question

In our practice data, 17 of 22 people missed this one. And 12 of them gave the same answer, because it sounds like the rule for everything else. A borrower writes to her servicer and asks who owns her loan. The letter arrives on June 4th. What is the ordinary deadline to answer? Pause. Which answer would you pick?

0:33Three clocks

First, the three clocks in Regulation X. Any written error notice or information request gets an acknowledgement within 5 business days. Most information requests get a full answer within 30 business days. But a request for the owner of the loan has its own short clock: 10 business days. And unlike the 30-day clock, it cannot be extended.

1:00Count it

Count it out. June 4th is a Thursday. Day one is Friday the 5th. Weekends do not count, so day 10 lands on Thursday, June 18th.

1:12The answers

Now the answers. A: 30 business days, like any other request. That is the general clock. The owner request has its own. Out. C: no answer is owed. The borrower is entitled to know who owns her loan. Out. D: 5 business days. Five days is the acknowledgement, not the answer. Out. That leaves B: 10 business days. The owner request has its own short clock.

1:47Recap

Five to acknowledge, ten for the owner, thirty for everything else. Next: does PMI cancellation reach a rental home? Subscribe so you catch it.

Sources

12 CFR 1024.35(d)
12 CFR 1024.36(c) and (d)(2)
EstatePass question bank: mlo-national-fed-respa-servicing-error-01

Independent study material. EstatePass is not affiliated with NMLS or CSBS, and nothing here is legal advice. Any lenders and borrowers in our episodes are fictional.