1. Live Contact – Servicers have significant flexibility to satisfy the
live contact requirement:
a. Through contact established by the borrower,
b. By sending written or electronic requests for contact, or
c. By providing information about loss mitigation in letters or during collection
calls.
2. Prolonged Delinquency – Servicers must exercise good faith to
establish live contact throughout the delinquency, however, what
constitutes good faith may be influenced by circumstances.
Example: in the case of an unresponsive borrower with six or more
consecutive delinquencies, good faith efforts to establish live contact might
include adding a sentence in the borrower's periodic statement or another
communication encouraging the borrower to contact the servicer.
26
Clarification of Early Intervention Obligations
