Early Intervention
Regulation X requires servicers to reach out to borrowers early in the
delinquency with both live contact and in writing and to maintain
borrower contact throughout the delinquency. The 2016 Amendment
clarifies that servicers have significant flexibility in providing early
intervention. It retains existing exemptions from the live contact early
intervention requirement and eliminates some exemptions from the
requirement for written early intervention. In all cases, the timing for
early intervention must be calculated based on the new
delinquency definition.
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