I am requesting you exempt small community banks from all aspects of this proposal. If a bank services its own mortgage loans, services less than 10,000 loans, is $10 Billion dollars or less in total assets, or some combination thereof it should be exempt from these requirements. As a small community bank it is necessary, and our belief, that it is beneficial to both us and our borrowers to provide them sufficient information about their loan payments, to process those payments as soon as practical, and exhaust all possibilities to help them when they cannot make payments as originally agreed. To place these requirements on banks such as ours is to require us to develop new formal systems for things we are already doing. The establishment of those systems is particularly burdensome for small institutions. Large institutions and servicers already have the systems and manpower to more easily put in place these requirements at a cost much less proportionate to the smaller institutions. Thank you.
Comment on CFPB-2012-0033-0019
This is comment on Proposed Rule
2012 Truth in Lending Act (Regulation Z) Mortgage Servicing
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