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On the new periodic statements, do we have to include a toll-free number if we are a community bank? – IBA Compliance Connection

IBA Compliance Connection

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On the new periodic statements, do we have to include a toll-free number if we are a community bank?

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If your institution qualifies as a “small servicer,” you will be exempt from all of the periodic statement requirements. 12 CFR 1026.41(e)(4). You will be considered a small servicer if your institution and any affiliates were servicing a total of 5,000 or fewer mortgage loans as of January 1 of this year, provided that your institution (or an affiliate) originated or currently owns those loans. 12 CFR 1026.41(e)(4)(ii). The loans that count towards the total are “closed-end consumer credit transactions secured by a dwelling.” Official Interpretations, 12 CFR 1026, Paragraph 41(e)(4)(ii), Comment 1.