No. There is no exception for abandoned properties in the RESPA prohibition on initiating a foreclosure action before the borrower is more than 120 days delinquent (provided that the property is the borrower's principal residence). 12 CFR 1026.41(f)(1)(i). The CFPB received requests from industry commenters to include such an exception, and the CFPB declined to do so, explaining:

Finally, the Bureau notes that several commenters requested that the Bureau exempt vacant or abandoned properties from the 120-day prohibition. . . . such a determination depends on the individual facts and circumstances, and may vary according applicable State law. . . . the Bureau believes any such test would inherently rely on a holistic determination based on individual facts and circumstances, and would not provide the clear guideline that the Bureau believes is appropriate with respect to the prohibition on foreclosure referral. . . . a number of borrower protection concerns could arise from affording servicers too much discretion in determining whether a property is abandoned or vacant. . . . it would be rare for a property to be determined abandoned or vacant earlier than the 120th day of delinquency.

For these reasons, the Bureau is not adopting an exclusion from the 120-day prohibition for vacant or abandoned properties.

Amendments to the 2013 Mortgage Rules, 78 Fed. Reg. 60381, 60407 (October 1, 2013).

However, the CFPB also went on to note that in some cases, there are instances where the 120-day waiting period would not apply to a vacant or abandoned property, because the RESPA servicing rules “apply only to a mortgage loan secured by property that is a borrower’s principal residence. See 12 CFR 1024.30(c)(2).” Id.