28
Safe Harbor
Concurrent with publication of the 2016 Servicing
Amendments, the Bureau issued an Advisory Opinion, creating
a safe harbor from liability under FDCPA section 805(c) when
servicers that are debt collectors subject to the FDCPA:
Provide modified written early intervention notices as
required by the new rule; and
Respond to borrower-initiated communications
concerning loss mitigation after the borrower has invoked
the cease communication right.
