I was recently at a conference and the speaker stated that even if you are a small servicer and are going to continue to send out coupon books instead of monthly statements, every one of your customers has to receive a coupon book even if they are ACH customers who never have received a coupon book. You would have to send them a coupon book stating that even though you are paying your payment ACH here’s your required coupon book. Is this correct information? I’m having trouble finding this about ACH customers.
If you qualify for the small servicer exemption the periodic statement requirements won’t apply so you would not be required to send coupon books. If you are using the coupon book exemption (only applies to fixed rate loans), then I would agree that you will need to send a coupon book to each borrower.