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Re: Small Servicer Exemption

#3066
rcooper
Keymaster

IMO, that may work for the requirements in Reg X, but probably wouldn’t for Reg Z. Reg Z doesn’t use the same definition of mortgage loan in 1026.41 as is used in Reg X. And if you’re wanting to use the small servicer exemption under 1026.41(e)(4) then I think you would have to use the definition of mortgage loan as defined in that section.