1. Sensitive Information - Servicers may withhold certain types
of sensitive information when responding to notices of error or
information requests that are submitted by confirmed successors
or that request information about potential or confirmed
successors in interest.
2. Safe Harbor - Concurrent with the release of the 2016 Servicing
Amendments, the Bureau issued an advisory opinion interpreting
"consumer" in FDCPA section 805 to include anyone defined in
Regulations X and Z as a confirmed successor. This provides a
safe harbor from liability under FDCPA section 805(b) for
communications by a servicer to a confirmed successor about the
mortgage loan in compliance with Regulations X and Z.
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Successors and Privacy
