{"meta":{"key":"r006--pass-01","task":"R006","title":"Federal mortgage servicing-transfer and ownership-transfer notices, payment-transition protections, and their limits","parent_title":"The debt lifecycle","edition":"pass-01","path":"/research/r006--pass-01/","kind":"split_pass","category":"subject","role":"primary_area","area_numbers":[6],"groups":["foundations"],"date":"2026-10-27","tables":16,"claims":66,"sources":24,"review_status":"accepted_with_limits","review_complete":true,"sha256":"ba3cb6c49b42a954fb5588af45f6052775222740caf0e254dd736270894d9b88","headings":["Federal mortgage servicing-transfer and ownership-transfer notices, payment-transition protections, and their limits","Check date, method, and limits","1. Comparison matrix","2. Source register","Register conventions","A. Statutes and current regulatory materials","B. Final rules, history, version evidence, and failed current-text retrievals","3. Atomic findings and claim table","Status key","A. Scope, products, actors, and successors","B. Servicing-transfer notices, timing, content, delivery, and models","C. Transition payments and proof boundaries","D. Ownership-transfer coverage, timing, content, exceptions, and delivery","E. Versions, history, and unresolved source issues","4. What the payment protection does—and what must be proved","5. Clearly hypothetical qualitative failure branches","6. Blank generic notice-audit worksheet","7. Granular coverage table","8. Read and failure log","Legal-status classification","9. Question → claim → source crosswalk","10. Self-check — not independent review","Specific parent holds preserved"],"generation_provenance":{"actual_route":"regular_chat_adaptive_models","actual_model":"GPT-6","actual_mode":"Pro","provenance_limit":"Actual documented capture labels only; missing labels remain unknown. No preferred setting is inferred as actual execution."},"public_id":"R006/pass-01","facets":{"geography":["us","us-federal"],"debt_type":["mortgage"],"stage":[],"subject":["ownership-transfer","policy-history"]},"scope":"SettleADebt R006 PASS-01 — FIRST FOCUSED A006 COMPONENT: US FEDERAL MORTGAGE SERVICING-TRANSFER AND OWNERSHIP-TRANSFER NOTICES, PAYMENT-TRANSITION PROTECTIONS, AND THEIR DISTINCT LIMITS. No actualloan/property/servicer/entityrecord investigation. Separate changeofservicerfromlegalownershipofdebt/securityandnoticefromassignmentproof.","pending_corrections":0},"markdown":"# SettleADebt R006 PASS-01\n\n## Federal mortgage servicing-transfer and ownership-transfer notices, payment-transition protections, and their limits\n\n**A transfer of servicing and a transfer of legal ownership of the debt are different events.** Either may occur alone, or both may occur together. Their notice duties must be tested separately. A servicing-transfer notice identifies changes in servicing arrangements; an ownership-transfer disclosure reports a qualifying acquisition of the debt. Neither notice, by itself, establishes a valid assignment, ownership of the security instrument, perfection, standing, the balance owed, or an actual default. The last point is a bounded inference from the disclosure provisions—not a ruling about the evidentiary value of any particular document. See C001 and C061 below. [Consumer Financial Protection Bureau+2](https://www.consumerfinance.gov/rules-policy/regulations/1024/33/?utm_source=chatgpt.com)\n\n**The payment-transition protection is conditional.** Regulation X protects a payment received by the former servicer within the specified transfer period and on or before the applicable payment deadline, including an instrument-authorized grace period. It does not create a universal payment holiday, amend the principal or interest rate, or establish that an unpaid or insufficient installment has been satisfied. [Consumer Financial Protection Bureau+1](https://www.consumerfinance.gov/rules-policy/regulations/1024/33/?utm_source=chatgpt.com)\n\n### Check date, method, and limits\n\n- **Actual public-primary-source check:** October 27, 2026, **America/Los_Angeles**. The last recorded clock observation during the principal source review was 14:15:22 PDT, corresponding to 21:15:22 UTC; subsequent historical-source verification occurred on the same date.\n- **Session provenance:** the session identifies the assistant as GPT-6 Astra Pro. I did not inspect a ChatGPT model selector, verify a product tier, or change models. I therefore do not certify an unseen “Regular Chat” UI selection.\n- **Research performed:** public statutes, official agency regulations and interpretations, annual CFR publications, final-rule material, and a generic model notice. No prior report or R002/R004 material supplied a foundation.\n- **No actual-record work:** no loan, borrower, property, provider, company, licensing, recording, litigation-record, or docket-status investigation; no identifier entry, records request, filing, contact, transaction, publication, or account change.\n- **No delegation or artifact workflow:** no subagents, browser control, local coordinator files, generated report files, or external research workflow.\n\n**Currentness remains bounded.** The retrieved House Title 12 pages report laws in effect through **Public Law 119-124, October 15, 2026**; the Title 15 page reports through **Public Law 119-134, October 20, 2026**. Those are compilation statements, not a completed audit of every enactment through October 27. Direct eCFR section retrieval failed. Official 2026 Regulation X material was retrieved; the “most recent” GovInfo route for §1026.39 returned the **January 1, 2025 edition**, supplemented here by the CFPB’s posted regulatory text and relevant final rules. [uscode.house.gov+5](https://uscode.house.gov/us/usc/119-124/t12/s2605/?utm_source=chatgpt.com)\n\n## 1. Comparison matrix\n\nReferences such as **C021** and **S009** below mean the full identifiers **R006-P1-C021** and **R006-P1-S009**.\n\n| Dimension | Servicing-transfer regime | Ownership-transfer regime |\n| --- | --- | --- |\n| Principal authorities | 12 USC §2605(b)–(d), with definitions in §2605(i); Regulation X §§1024.30–.33 and necessary adjacent provisions. | 15 USC §1641(g), with relevant §1641(f); Regulation Z §1026.39 and necessary definitions and interpretations. |\n| Actor owing the transfer notice | Ordinarily **each transferor and transferee servicer**; a qualifying combined notice can satisfy both duties. C018–C023. | The acquiring **covered person**. These provisions do not establish a corresponding general seller-side ownership notice. C038, C042. |\n| Trigger | Assignment, sale, or transfer of **servicing**, subject to specified exclusions. C012, C018–C020. | Acquisition of **legal title to an existing debt obligation**, with the covered-person threshold and exceptions. C042–C049. |\n| Product boundary | Regulation X Subpart C uses “mortgage loan”: a federally related mortgage loan subject to §1024.5(b), **excluding open-end home-equity plans**. Section 2605 itself uses “federally related mortgage loan”; its text does not reproduce that express HELOC exclusion. C002–C008. | Section 1641(g) refers to consumer credit secured by the consumer’s **principal dwelling**. Current §1026.39 separately covers open-end consumer credit secured by a principal dwelling and closed-end consumer credit secured by **a dwelling or real property**. C038–C041. |\n| Ordinary clock | Transferor: at least **15 calendar days before** the servicing effective date. Transferee: no later than **15 calendar days after**. Combined servicing notice: at least **15 calendar days before**. C021. | Mail or deliver by the **30th calendar day following** the transfer date recognized under §1026.39(b)(2). C045. |\n| Clock-defining event | Generally, when the borrower’s payment is first due to the transferee servicer; special agreed-date definition for reverse mortgages. C013. | Acquiring party’s recognized acquisition date or transferring party’s recognized transfer date, at the covered person’s option under the rule. C045. |\n| Core content | Effective date; both servicing contacts; payment acceptance transition dates; optional-insurance effects and actions; statement about unchanged nonservicing terms. C026–C028. | Loan identification; new owner contact; transfer date; authorized contact; recording-location disclosure or permitted alternative; applicable partial-payment policy. C052–C056. |\n| Conditional exceptions | Specified unchanged-payment affiliate/merger/master-servicer transfers; FHA provision; specified extended timing; settlement timing; applicable successor procedure. C016–C023. | Timely disposition of all interest; qualifying repurchase arrangement; qualifying partial-interest acquisition without the specified contact change; successor provision. C047–C049, C058. |\n| Payment-transition protection | Conditional §1024.33(c)(1) protection, plus separate prompt-forward-or-return duty under (c)(2). C032–C037. | Section 1026.39 does **not itself create the servicing-transfer 60-day protection**. Its partial-payment provision is a disclosure requirement. C056, C061. |\n| What a notice cannot establish by itself | Debt ownership, valid assignment, secured rights, perfection, balance, default, or standing. | Actual valid acquisition, enforceable security rights, recording validity, balance, default, or standing. C061. |\n\nThe matrix is a navigation aid. The conditions and qualifications in the atomic findings control.\n\n## 2. Source register\n\n### Register conventions\n\n**All entries were checked on October 27, 2026 PDT; jurisdiction is United States federal law.** That date is an access date, not an enactment or effective date.\n\n- **Fresh** means retrieved and read during this assignment.\n- **Reused** means reused within this assignment after that fresh read—not imported from another report.\n- **Selected** means only the identified portions were read.\n- **Discovery** means located but not used as operative authority.\n- HTML sources have **no printed page or PDF index**.\n- PDF indexes below are **zero-based**.\n- Multiple sections, reproductions, or editions of the same authority are grouped. They are **not counted as independent corroboration**.\n- A screenshot response is not necessarily inspectable image content. The specific image limitation is recorded in S011–S012 and the failure log.\n\n### A. Statutes and current regulatory materials\n\n| Source ID | Issuer/title and complete literal HTTPS URL(s) | Exact read bounds / pinpoint | Version and effective predicate; read status and currentness limit |\n| --- | --- | --- | --- |\n| **R006-P1-S001** | House Office of Law Revision Counsel, **12 USC §2605, Servicing of mortgage loans and administration of escrow accounts**. [https://uscode.house.gov/us/usc/119-124/t12/s2605/](https://uscode.house.gov/us/usc/119-124/t12/s2605/?utm_source=chatgpt.com) Earlier GPO compilation: [https://www.govinfo.gov/content/pkg/USCODE-2024-title12/html/USCODE-2024-title12-chap27-sec2605.htm](https://www.govinfo.gov/content/pkg/USCODE-2024-title12/html/USCODE-2024-title12-chap27-sec2605.htm?utm_source=chatgpt.com) | Complete necessary **(b), (c), (d), (h), (i), (j)**; (a) for the application/transfer distinction. Adjacent (e)(3) read only to distinguish its separate credit-reporting clock. Other displayed provisions were not analyzed as assigned subjects. | House: laws in effect through **PL119-124, October 15, 2026**. GPO: 2024 edition, initially read, then superseded for current statutory wording by the House read. Fresh; reused. Statutory notice and payment triggers are in the cited subsections. No full post-compilation session-law audit. [uscode.house.gov+2](https://uscode.house.gov/us/usc/119-124/t12/s2605/?utm_source=chatgpt.com) |\n| **R006-P1-S002** | House OLRC, **12 USC §§2602 and 2606**, definitions and exempted transactions. [https://uscode.house.gov/us/usc/119-124/t12/s2602/](https://uscode.house.gov/us/usc/119-124/t12/s2602/?utm_source=chatgpt.com) [https://uscode.house.gov/us/usc/119-124/t12/s2606/](https://uscode.house.gov/us/usc/119-124/t12/s2606/?utm_source=chatgpt.com) Earlier reads: [https://www.govinfo.gov/content/pkg/USCODE-2024-title12/html/USCODE-2024-title12-chap27-sec2602.htm](https://www.govinfo.gov/content/pkg/USCODE-2024-title12/html/USCODE-2024-title12-chap27-sec2602.htm?utm_source=chatgpt.com) [https://www.govinfo.gov/link/uscode/12/2606](https://www.govinfo.gov/link/uscode/12/2606?utm_source=chatgpt.com) | §2602 **(1), (5)** and relevant editorial notes; complete §2606 **(a)–(b)**. The §2606 GovInfo PDF was **printed p.1452, index 0**, parsed text only. | House: through **PL119-124, October 15, 2026**. Earlier §2602 HTML: 2024. Edition of the isolated §2606 link PDF was not independently established; the later House read supplies the reported compilation version. Fresh; reused. [uscode.house.gov+2](https://uscode.house.gov/us/usc/119-124/t12/s2602/?utm_source=chatgpt.com) |\n| **R006-P1-S003** | House OLRC, **15 USC §1641, Liability of assignees**. [https://uscode.house.gov/us/usc/119-134/t15/s1641/](https://uscode.house.gov/us/usc/119-134/t15/s1641/?utm_source=chatgpt.com) Earlier GPO compilation: [https://www.govinfo.gov/content/pkg/USCODE-2024-title15/html/USCODE-2024-title15-chap41-subchapI-partB-sec1641.htm](https://www.govinfo.gov/content/pkg/USCODE-2024-title15/html/USCODE-2024-title15-chap41-subchapI-partB-sec1641.htm?utm_source=chatgpt.com) | Complete necessary **(f) and (g)**; source credit and amendment notes. Other liability provisions displayed on the page are outside this component. | House: through **PL119-134, October 20, 2026**. Subsection (g) added by PL111-22, May 20, 2009. Earlier GPO 2024 text freshly read, then checked against House. No remedies analysis or full later-law audit. [uscode.house.gov](https://uscode.house.gov/us/usc/119-134/t15/s1641/?utm_source=chatgpt.com) |\n| **R006-P1-S004** | CFPB, **Regulation X §1024.2, Definitions**. [https://www.consumerfinance.gov/rules-policy/regulations/1024/2/](https://www.consumerfinance.gov/rules-policy/regulations/1024/2/?utm_source=chatgpt.com) | Complete necessary definitions of **business day; effective date of transfer; federally related mortgage loan; servicer; servicing; State; table funding**, and relevant lender/dealer/broker definitions. | Agency page labeled current; part-version limitation in S022. Fresh selected-body read. Necessary federal nexus, property, actor, and reverse-mortgage conditions read in full; no general underwriting analysis. [Consumer Financial Protection Bureau+1](https://www.consumerfinance.gov/rules-policy/regulations/1024/2/?utm_source=chatgpt.com) |\n| **R006-P1-S005** | CFPB, **§1024.5, Coverage of RESPA**. [https://www.consumerfinance.gov/rules-policy/regulations/1024/5/](https://www.consumerfinance.gov/rules-policy/regulations/1024/5/?utm_source=chatgpt.com) | Complete **(a)–(d)** and relevant embedded official interpretations, particularly **(b)(2)–(7), (c)(1), (c)(4), (d)**. | Agency-current label, subject to S022. Fresh full operative section read. Exceptions are section-specific; secondary-market and partial exemptions cannot be generalized. [Consumer Financial Protection Bureau](https://www.consumerfinance.gov/rules-policy/regulations/1024/5/?utm_source=chatgpt.com) |\n| **R006-P1-S006** | CFPB, **§1024.11, Mailing**. [https://www.consumerfinance.gov/rules-policy/regulations/1024/11/](https://www.consumerfinance.gov/rules-policy/regulations/1024/11/?utm_source=chatgpt.com) | Entire operative mailing paragraph. | Agency-current label. Fresh full-body read. Applies by its terms to mailing provisions of **“this part”**; used together with transfer-specific address interpretation, not as a payment-receipt rule. [Consumer Financial Protection Bureau](https://www.consumerfinance.gov/rules-policy/regulations/1024/11/?utm_source=chatgpt.com) |\n| **R006-P1-S007** | CFPB, **§§1024.30–.31**, scope, definitions, and official interpretations. [https://www.consumerfinance.gov/rules-policy/regulations/1024/30/](https://www.consumerfinance.gov/rules-policy/regulations/1024/30/?utm_source=chatgpt.com) [https://www.consumerfinance.gov/rules-policy/regulations/1024/31/](https://www.consumerfinance.gov/rules-policy/regulations/1024/31/?utm_source=chatgpt.com) [https://www.consumerfinance.gov/rules-policy/regulations/1024/interp-31/](https://www.consumerfinance.gov/rules-policy/regulations/1024/interp-31/?utm_source=chatgpt.com) | §30 **(a)–(d)** and comments; §31 necessary definitions, including day, mortgage loan, master/subservicer, transferor/transferee, successor and confirmed successor; official **Delinquency comments 1–4** and **Successor comments 1–2**. | Fresh; reused. The agency §31 page still displays the later-removed COVID definition. That stale item is not used; S011 and S021 address the discrepancy. Successor amendments relevant here took effect **April 19, 2018**. [Consumer Financial Protection Bureau+3](https://www.consumerfinance.gov/rules-policy/regulations/1024/30/?utm_source=chatgpt.com) |\n| **R006-P1-S008** | CFPB, **§1024.32, General disclosure requirements**. [https://www.consumerfinance.gov/rules-policy/regulations/1024/32/](https://www.consumerfinance.gov/rules-policy/regulations/1024/32/?utm_source=chatgpt.com) | Complete **(a)–(c)** and embedded interpretations, including **32(c)(1)-1; 32(c)(2)-1 and -2**. | Fresh full necessary body/comments. Successor procedure effective **April 19, 2018**, S019. No inference that a generic acknowledgment establishes actual personal liability or valid security rights. [Consumer Financial Protection Bureau+2](https://www.consumerfinance.gov/rules-policy/regulations/1024/32/?utm_source=chatgpt.com) |\n| **R006-P1-S009** | CFPB, **§1024.33, Mortgage servicing transfers**, and Supplement I. [https://www.consumerfinance.gov/rules-policy/regulations/1024/33/](https://www.consumerfinance.gov/rules-policy/regulations/1024/33/?utm_source=chatgpt.com) [https://www.consumerfinance.gov/rules-policy/regulations/1024/interp-33/](https://www.consumerfinance.gov/rules-policy/regulations/1024/interp-33/?utm_source=chatgpt.com) | Complete **(a)–(d)**; comments **33(a)-1 through -3; 33(b)(3)-1; 33(c)(1)-1 and -2**. | Fresh complete operative section and necessary comments. Current posting checked against 2026 annual CFR §33. Core 2013 servicing rule effective **January 10, 2014**; later amendment/history separately identified below. [Consumer Financial Protection Bureau+2](https://www.consumerfinance.gov/rules-policy/regulations/1024/33/?utm_source=chatgpt.com) |\n| **R006-P1-S010** | CFPB, **Appendix MS, MS-2, and official model instructions**. [https://www.consumerfinance.gov/rules-policy/regulations/1024/ms/](https://www.consumerfinance.gov/rules-policy/regulations/1024/ms/?utm_source=chatgpt.com) [https://www.consumerfinance.gov/rules-policy/regulations/1024/ms2/](https://www.consumerfinance.gov/rules-policy/regulations/1024/ms2/?utm_source=chatgpt.com) [https://www.consumerfinance.gov/rules-policy/regulations/1024/interp-ms/](https://www.consumerfinance.gov/rules-policy/regulations/1024/interp-ms/?utm_source=chatgpt.com) | Entire posted **MS-2** notice text. Appendix MS general instructions **1–2**, with complete continuation/examples verified in annual CFR rather than assuming the website excerpt was complete. | Fresh. Current generic model, not an actual notice. Model use is optional and conditional. No H-25 form was used or claimed to have been inspected. [Consumer Financial Protection Bureau+2](https://www.consumerfinance.gov/rules-policy/regulations/1024/ms2/?utm_source=chatgpt.com) |\n| **R006-P1-S011** | OFR/GPO, **2026 annual CFR, Regulation X**. [https://www.govinfo.gov/content/pkg/CFR-2026-title12-vol8/pdf/CFR-2026-title12-vol8-sec1024-33.pdf](https://www.govinfo.gov/content/pkg/CFR-2026-title12-vol8/pdf/CFR-2026-title12-vol8-sec1024-33.pdf?utm_source=chatgpt.com) [https://www.govinfo.gov/content/pkg/CFR-2026-title12-vol8/pdf/CFR-2026-title12-vol8-part1024.pdf](https://www.govinfo.gov/content/pkg/CFR-2026-title12-vol8/pdf/CFR-2026-title12-vol8-part1024.pdf?utm_source=chatgpt.com) | §33 granule: **printed pp.704–706, indexes 0–2**, complete §33. Full-part PDF: selected §§30–32 text **pp.702–704, indexes 28–30**; relevant comments **pp.756–758, indexes 82–84**; complete MS-2 **pp.752–753, indexes 78–79**; complete general MS instructions **p.782, index 108**. | **January 1, 2026 edition**; 110-page full-part file not read in full. Parsed-text read. Screenshot requests for indexes 78–79 returned display markers without inspectable image blocks through this tool: **no pixel-level verification claimed**. Fresh; same-edition reproductions, not independent corroboration. [govinfo.gov+3](https://www.govinfo.gov/content/pkg/CFR-2026-title12-vol8/pdf/CFR-2026-title12-vol8-sec1024-33.pdf?utm_source=chatgpt.com) |\n| **R006-P1-S012** | OFR/GPO, **2025 annual CFR, Regulation X**, earlier verification copies. [https://www.govinfo.gov/content/pkg/CFR-2025-title12-vol8/pdf/CFR-2025-title12-vol8-sec1024-33.pdf](https://www.govinfo.gov/content/pkg/CFR-2025-title12-vol8/pdf/CFR-2025-title12-vol8-sec1024-33.pdf?utm_source=chatgpt.com) [https://www.govinfo.gov/content/pkg/CFR-2025-title12-vol8/pdf/CFR-2025-title12-vol8-part1024.pdf](https://www.govinfo.gov/content/pkg/CFR-2025-title12-vol8/pdf/CFR-2025-title12-vol8-part1024.pdf?utm_source=chatgpt.com) [https://www.govinfo.gov/content/pkg/CFR-2025-title12-vol8/pdf/CFR-2025-title12-vol8-part1024-appMS.pdf](https://www.govinfo.gov/content/pkg/CFR-2025-title12-vol8/pdf/CFR-2025-title12-vol8-part1024-appMS.pdf?utm_source=chatgpt.com) | Selected §33; complete MS-2 parsed across **pp.754–755, full-part indexes 80–81**; general MS instructions **p.785, index 111**. Isolated appendix granule contains **p.754 only, index 0**—it is not the complete MS-2. | **January 1, 2025 edition**, supplanted for annual-edition verification by S011. Screenshot retrieval included a timeout/recovery; no additional pixel-read claim is necessary or made. The 113-page full part was not fully read. [govinfo.gov+2](https://www.govinfo.gov/content/pkg/CFR-2025-title12-vol8/pdf/CFR-2025-title12-vol8-part1024.pdf?utm_source=chatgpt.com) |\n| **R006-P1-S013** | CFPB, **Regulation Z §§1026.2–.3**, necessary definitions and exemptions. [https://www.consumerfinance.gov/rules-policy/regulations/1026/2/](https://www.consumerfinance.gov/rules-policy/regulations/1026/2/?utm_source=chatgpt.com) [https://www.consumerfinance.gov/rules-policy/regulations/1026/3/](https://www.consumerfinance.gov/rules-policy/regulations/1026/3/?utm_source=chatgpt.com) | §2 **(a)(6), (10)–(12), (19), (22), (27)** and relevant consumer, dwelling, person, trust, and successor comments; §3 **(a)(1)–(2)** and corresponding interpretations. | Fresh selected-body read. Consumer-purpose and organizational-credit boundaries examined only as necessary for §39; no comprehensive origination, underwriting, or general Regulation Z gateway rerun. [Consumer Financial Protection Bureau+3](https://www.consumerfinance.gov/rules-policy/regulations/1026/2/?utm_source=chatgpt.com) |\n| **R006-P1-S014** | CFPB, **§1026.39, Mortgage transfer disclosures**, and Supplement I. [https://www.consumerfinance.gov/rules-policy/regulations/1026/39/](https://www.consumerfinance.gov/rules-policy/regulations/1026/39/?utm_source=chatgpt.com) [https://www.consumerfinance.gov/rules-policy/regulations/1026/interp-39/](https://www.consumerfinance.gov/rules-policy/regulations/1026/interp-39/?utm_source=chatgpt.com) | Complete **(a)–(f)** and relevant embedded official comments: **39(a)(1)-1–4; (a)(2)-1; (b)(1)-1; (b)(4)-1–3; (b)(5)-1–4; (c)(1)-1–2; (c)(2)-1; (c)(3)-1–2; (d)-1–2; (d)(1)-1; (d)(1)(i)-1; (d)(1)(ii)-1; (d)(3)-1–2; (d)(4)-1; (d)(5)-1; (e)-1**. | Fresh complete operative body/comments through the integrated page; standalone interpretation page used as associated source, not separate corroboration. Agency-current label subject to S022. Two textual inconsistencies are expressly recorded below. [Consumer Financial Protection Bureau+3](https://www.consumerfinance.gov/rules-policy/regulations/1026/39/?utm_source=chatgpt.com) |\n| **R006-P1-S015** | CFPB, **§1026.1**, necessary implementation provisions and comments. [https://www.consumerfinance.gov/rules-policy/regulations/1026/1/](https://www.consumerfinance.gov/rules-policy/regulations/1026/1/?utm_source=chatgpt.com) | **(c)(5)**; necessary **(d)(5)** material and comment **1(d)(5)-1**, particularly the post-consummation treatment of **§39(d)(5)**. | Fresh selected read. Partial-payment disclosure implementation: October 3, 2015 transition; triggering conditions on or after **October 1, 2018** apply regardless of application date. No general TRID analysis. [Consumer Financial Protection Bureau](https://www.consumerfinance.gov/rules-policy/regulations/1026/1/?utm_source=chatgpt.com) |\n| **R006-P1-S016** | OFR/GPO, **2025 annual CFR §1026.39**. [https://www.govinfo.gov/content/pkg/CFR-2025-title12-vol9/pdf/CFR-2025-title12-vol9-sec1026-39.pdf](https://www.govinfo.gov/content/pkg/CFR-2025-title12-vol9/pdf/CFR-2025-title12-vol9-sec1026-39.pdf?utm_source=chatgpt.com) [https://www.govinfo.gov/link/cfr/12/1026?link-type=pdf&sectionnum=39&year=mostrecent](https://www.govinfo.gov/link/cfr/12/1026?link-type=pdf&sectionnum=39&year=mostrecent&utm_source=chatgpt.com) | Complete §39, **printed pp.139–141, indexes 0–2**; neighboring §38/§40 fragments not treated as complete reads. | Both routes returned the **January 1, 2025 edition**. Fresh parsed-text read; no image inspection. “Most recent” routing is not proof that a 2026 edition does not exist. [govinfo.gov+1](https://www.govinfo.gov/content/pkg/CFR-2025-title12-vol9/pdf/CFR-2025-title12-vol9-sec1026-39.pdf?utm_source=chatgpt.com) |\n\n### B. Final rules, history, version evidence, and failed current-text retrievals\n\n| Source ID | Issuer/title and complete literal HTTPS URL(s) | Exact read bounds / pinpoint | Version/effective predicate; status and limits |\n| --- | --- | --- | --- |\n| **R006-P1-S017** | CFPB/OFR/GPO, **Mortgage Servicing Rules Under RESPA (Regulation X), 2013 final rule**. [https://www.govinfo.gov/content/pkg/FR-2013-02-14/pdf/2013-01248.pdf](https://www.govinfo.gov/content/pkg/FR-2013-02-14/pdf/2013-01248.pdf?utm_source=chatgpt.com) | Front effective-date text; selected §33 discussion **printed pp.10727–10734, indexes 31–38**; MS model discussion **p.10839, index 143**. Particularly payment-address treatment, complaint-resolution language, retained 60-day paragraph, and forwarding/return. | Published February 14, 2013; relevant servicing rule effective **January 10, 2014**. Historical final-rule explanation, not a substitute for current codified text. The 204-page PDF was not fully read. No case cited inside its preamble was treated as a read opinion. [govinfo.gov+2](https://www.govinfo.gov/content/pkg/FR-2013-02-14/pdf/2013-01248.pdf?utm_source=chatgpt.com) |\n| **R006-P1-S018** | CFPB/OFR/GPO, **Integrated Mortgage Disclosures, 2013 final rule**. [https://www.govinfo.gov/content/pkg/FR-2013-12-31/html/2013-28210.htm](https://www.govinfo.gov/content/pkg/FR-2013-12-31/html/2013-28210.htm?utm_source=chatgpt.com) | Selected §39 discussion **printed pp.80058–80060**; amendment **p.80130**; comments **p.80363**. HTML printed-page markers, **no PDF index**. | Final amendment expanded closed-end scope and added partial-payment disclosure. Original implementation dates were later modified; S015 supplies the relevant operative transition explanation. Selected body read, not the entire large rule. [govinfo.gov+2](https://www.govinfo.gov/content/pkg/FR-2013-12-31/html/2013-28210.htm?utm_source=chatgpt.com) |\n| **R006-P1-S019** | CFPB/OFR/GPO, **2016 Mortgage Servicing Amendments**. [https://www.govinfo.gov/content/pkg/FR-2016-10-19/pdf/2016-18901.pdf](https://www.govinfo.gov/content/pkg/FR-2016-10-19/pdf/2016-18901.pdf?utm_source=chatgpt.com) | Front dates; selected successor amendments/discussion; §39(f) discussion **p.72299, index 139**; instruction 22 and §39(f) **p.72388, index 228**. | Published October 19, 2016. Relevant successor provisions effective **April 19, 2018**, distinct from the rule’s general October 19, 2017 date. Selected read of a 242-page PDF. [govinfo.gov+1](https://www.govinfo.gov/content/pkg/FR-2016-10-19/pdf/2016-18901.pdf?utm_source=chatgpt.com) |\n| **R006-P1-S020** | Federal Reserve/OFR/GPO, **2010 Regulation Z final rule and official staff commentary, former §226.39**. [https://www.govinfo.gov/content/pkg/FR-2010-09-24/pdf/2010-20664.pdf](https://www.govinfo.gov/content/pkg/FR-2010-09-24/pdf/2010-20664.pdf?utm_source=chatgpt.com) | Front matter **p.58489/index 0**; selected ownership, multiple-transfer, exception and agent discussions **pp.58491–58498/indexes 2–9**; effective-date discussion **p.58500/index 11**; relevant former-rule/comment excerpts **pp.58501–58504/indexes 12–15**. | Historical authority only. Front dates say January 1, 2011; §VI says effective October 25, 2010 with January 1, 2011 mandatory compliance. **That internal historical-date discrepancy is preserved, not resolved.** Both passages distinguish the statute’s May 20, 2009 enactment/effect. Current §1026.39 controls this report. [govinfo.gov+2](https://www.govinfo.gov/content/pkg/FR-2010-09-24/pdf/2010-20664.pdf?utm_source=chatgpt.com) |\n| **R006-P1-S021** | CFPB/OFR/GPO, **2025 COVID-era Regulation X rescission, interim final rule**. [https://www.govinfo.gov/content/pkg/FR-2025-05-16/pdf/2025-08643.pdf](https://www.govinfo.gov/content/pkg/FR-2025-05-16/pdf/2025-08643.pdf?utm_source=chatgpt.com) [https://www.federalregister.gov/documents/2025/05/16/2025-08643/protections-for-borrowers-affected-by-the-covid-19-emergency-under-the-real-estate-settlement](https://www.federalregister.gov/documents/2025/05/16/2025-08643/protections-for-borrowers-affected-by-the-covid-19-emergency-under-the-real-estate-settlement?utm_source=chatgpt.com) | Effective-date text **p.20791/index 0**; instruction 2 removing the §31 COVID definition **p.20792/index 1**; amendment list and necessary cross-reference context. | **Interim final**, effective **July 15, 2025**; not merely a proposal. Used to identify the agency-page currency discrepancy, not to reopen loss mitigation or foreclosure subjects. Official PDF checked; no claim to have read the complete five-page PDF. [govinfo.gov+1](https://www.govinfo.gov/content/pkg/FR-2025-05-16/pdf/2025-08643.pdf?utm_source=chatgpt.com) |\n| **R006-P1-S022** | CFPB, regulation version lists. [https://www.consumerfinance.gov/rules-policy/regulations/1024/versions/33/](https://www.consumerfinance.gov/rules-policy/regulations/1024/versions/33/?utm_source=chatgpt.com) [https://www.consumerfinance.gov/rules-policy/regulations/1026/versions/39/](https://www.consumerfinance.gov/rules-policy/regulations/1026/versions/39/?utm_source=chatgpt.com) | Version-list labels only. | Retrieved lists identify **April 19, 2023** for Regulation X and **April 8, 2026** for Regulation Z as current versions. These are **part-level website labels**, not proof of each section’s amendment date or complete legal currency. Fresh metadata read. [Consumer Financial Protection Bureau+1](https://www.consumerfinance.gov/rules-policy/regulations/1024/versions/33/?utm_source=chatgpt.com) |\n| **R006-P1-S023** | OFR eCFR section retrieval attempts. [https://www.ecfr.gov/current/title-12/chapter-X/part-1024/section-1024.33](https://www.ecfr.gov/current/title-12/chapter-X/part-1024/section-1024.33) [https://www.ecfr.gov/current/title-12/chapter-X/part-1026/section-1026.39](https://www.ecfr.gov/current/title-12/chapter-X/part-1026/section-1026.39) [https://ecfr.federalregister.gov/current/title-12/chapter-X/part-1024/section-1024.33](https://ecfr.federalregister.gov/current/title-12/chapter-X/part-1024/section-1024.33) [https://ecfr.federalregister.gov/current/title-12/chapter-X/part-1026/section-1026.39](https://ecfr.federalregister.gov/current/title-12/chapter-X/part-1026/section-1026.39) | **No operative body retrieved through these routes.** | Failure, not evidence of no rule. Annual CFR, agency text, and final rules supplied the substantive reads. No CAPTCHA or security workaround attempted. |\n| **R006-P1-S024** | GovInfo attempted **2026 §1026.39** granule. [https://www.govinfo.gov/content/pkg/CFR-2026-title12-vol9/pdf/CFR-2026-title12-vol9-sec1026-39.pdf](https://www.govinfo.gov/content/pkg/CFR-2026-title12-vol9/pdf/CFR-2026-title12-vol9-sec1026-39.pdf) | No body retrieved. | Failure. The alternative most-recent route returned S016’s 2025 edition. A fully verified 2026 annual §39 granule remains a precise source gap. |\n\n## 3. Atomic findings and claim table\n\n### Status key\n\n- **S:** statutory text.\n- **R:** regulatory text.\n- **O:** official interpretation.\n- **H:** historical final-rule explanation or implementation history.\n- **I:** expressly identified inference.\n- **U:** unresolved fact or source issue.\n\n“Current” below means the retrieved operative sources subject to the currentness qualifications above—not an assertion that all possible later legal developments have been exhausted.\n\n### A. Scope, products, actors, and successors\n\n| Claim ID | Area and precise claim | Trigger, conditions, and exceptions | Source pinpoint | Status / limit |\n| --- | --- | --- | --- | --- |\n| **R006-P1-C001** | Servicing rights, ownership of the debt, and ownership of property securing the debt are separate subjects in these provisions. | A single transaction may affect more than one, but one label does not establish the others. | S001 §2605(i); S007 §31; S014 §39(a)(1). | R/S; separation and proof limitation are I. |\n| **R006-P1-C002** | RESPA’s statutory federally related mortgage-loan definition requires qualifying residential collateral and a specified federal/lender nexus. | First or subordinate lien on principally one-to-four-family residential real property; non-temporary financing; federally insured/regulated lender, federal assistance, intended specified secondary-market sale, or qualifying creditor making/investing **more than $1 million per year** in residential real-estate loans. State agencies are excluded from that last creditor branch. | S002 §2602(1)(A)–(B). | S; collateral alone is insufficient. |\n| **R006-P1-C003** | Regulation X adds necessary detail concerning residential structures, manufactured homes, dealer/broker originations, reverse mortgages, and financed land/installment contracts. | Apply each §2 definition branch. The security must be in a defined “State,” including DC, Puerto Rico, and US territories/possessions. A manufactured-home or contract-for-deed label alone is insufficient. | S004 §2, “Federally related mortgage loan” (1)–(3), “State.” | R; no foreign-law or actual-product determination. |\n| **R006-P1-C004** | Primarily business, commercial, or agricultural credit is excluded under the relevant RESPA provisions; credit to government/agencies/instrumentalities is statutorily excluded. | Purpose is assessed under the specified Regulation Z interpretation, not simply a document’s “business loan” label. | S002 §2606(a)–(b); S005 §5(b)(2); S013 §3(a). | S/R/O; no actual purpose classification. |\n| **R006-P1-C005** | The temporary-financing exemption has operative qualifications. | It does not cover qualifying construction used as, convertible by the same lender to, or committed to permanent financing, or financing transfer to the first user. Qualifying construction of **two years or more**, except a bona fide builder loan, is covered. Bridge/swing financing is excluded as specified. | S005 §5(b)(3). | R; no universal “construction loan” result. |\n| **R006-P1-C006** | Other §5(b) exclusions are conditional. | Vacant/unimproved land: exception where proceeds will fund the specified structure/home within **two years**. Assumption: distinguish no lender approval right from required and obtained approval. Conversion: original-instrument-consistent changes without a required new note. | S005 §5(b)(4)–(6). | R; transaction facts remain unknown. |\n| **R006-P1-C007** | The secondary-market exemption expressly preserves §2605 and Subpart C. | Table-funded transactions and the specified initial dealer-loan transactions are not secondary-market transactions. Section 5(d)’s partial exemptions include §33(a), not a blanket exemption from §33(b)–(c). | S005 §5(b)(7), (d). | R; an ownership sale does not automatically escape servicing provisions. |\n| **R006-P1-C008** | Subpart C expressly excludes open-end home-equity plans; §33 has no general principal-residence restriction. | The principal-residence restriction in §30(c)(2) concerns §§39–41. Small-servicer, reverse-mortgage, and qualified-lender exemptions in §30(b) concern §§38–41, subject to their terms—not a blanket §33 exemption. | S007 §§30(b)–(c), 31 “Mortgage loan.” | R/O. The HELOC exclusion is regulatory wording, not an express phrase in §2605(b)–(d). |\n| **R006-P1-C009** | A servicer is the person responsible for servicing, including a maker or holder that also services. | Servicing concerns receiving scheduled payments and making required onward payments; Regulation X includes payments **to** the borrower for reverse mortgages. | S001 §2605(i)(2)–(3); S004 “Servicer,” “Servicing.” | S/R; being an owner alone does not establish servicing. |\n| **R006-P1-C010** | Section 2605(i)(2) has named federal-actor exclusions. | FDIC/RTC specified asset or receivership/conservatorship functions; and the named Ginnie Mae/Fannie Mae/Freddie Mac/RTC/FDIC actors where the specified predecessor servicing termination, bankruptcy, or FDIC/RTC proceeding occurred. | S001 §2605(i)(2)(A)–(B). | S; statutory RTC wording is reported, not silently modernized. |\n| **R006-P1-C011** | Regulation X’s servicer exclusions must be read separately from the statutory list. | Specified FDIC functions; specified NCUA functions; and the named FNMA, Freddie Mac, FDIC, HUD—including GNMA/FHA—NCUA, Farm Service Agency, and VA actors in the enumerated cause-termination, bankruptcy, FDIC, or NCUA circumstances. | S004 “Servicer” (1)–(3). | R; government involvement or insurance alone does not establish an exclusion. |\n| **R006-P1-C012** | Master servicer, subservicer, transferor, and transferee are distinct functional definitions. | Master owns the servicing right; subservicer performs for the master without owning it. Transferor transfers, and transferee obtains, the right to perform servicing under an agreement/understanding. Specified table-funding brokers/dealers can be transferors. | S007 §31 definitions. | R; no blanket “mere subservicing” exemption follows. |\n| **R006-P1-C013** | The servicing effective date generally is the date payment is first due to the transferee pursuant to the servicing transfer. | For a HECM/reverse mortgage, §2 uses the transfer date agreed by the two servicers. | S001 §2605(i)(1); S004 “Effective date of transfer.” | S/R; not automatically sale, recording, letter, or receipt date. |\n| **R006-P1-C014** | A successor in interest here receives a qualifying interest in the secured property, not the creditor’s debt. | Five categories: specified death/survivorship transfers; relative after borrower’s death; spouse/children ownership; specified marital dissolution/separation/property settlement; qualifying inter vivos trust without occupancy-right transfer. Confirmation requires identity and property-interest confirmation by the servicer. | S007 §31; Successor comments 1–2. | R/O; trust beneficiaries, rather than the trust itself, are addressed by the trust comment. |\n| **R006-P1-C015** | A confirmed successor is treated as a borrower for the relevant Regulation X provisions without mandatory assumption. | That treatment does not determine contractual liability. Applicable obligations to the original borrower continue. | S007 §30(d), comments 1–3. | R/O; property succession is not debt acquisition by a covered person. |\n| **R006-P1-C016** | Section 32(c)’s optional notice-and-acknowledgment procedure can condition specified communications to a confirmed successor who is not liable. | Requires a compliant notice and **separate** acknowledgment limited to the permitted subjects: confirmation; nonliability/conditional security explanation; notice entitlement; request/understanding; no return deadline; and explanation of retained error, information, and payoff-request rights with addresses. | S008 §32(c)(1)(i)–(v). | R; merely saying “no assumption” does not establish this exception. |\n| **R006-P1-C017** | The successor communication limitations are narrow. | With a compliant procedure, specified disclosures may be withheld until assumption or acknowledgment; revocation has its stated effect. Copies must be available on oral/written request. Providing the **same specific disclosure** to another borrower can satisfy §32(c)(4). | S008 §32(c)(2)–(4), comments 32(c)(2)-1–2. | R/O; no blanket disappearance of successor or original-borrower rights. |\n\n### B. Servicing-transfer notices, timing, content, delivery, and models\n\n| Claim ID | Area and precise claim | Trigger, conditions, and exceptions | Source pinpoint | Status / limit |\n| --- | --- | --- | --- | --- |\n| **R006-P1-C018** | Ordinarily, both transferor and transferee owe a servicing-transfer notice. | A qualifying mortgage servicing assignment, sale, or transfer; apply coverage, actor, transfer, and successor exceptions first. | S001 §2605(b)(1), (c)(1); S009 §33(b)(1). | S/R; a change of debt owner is not required. |\n| **R006-P1-C019** | Three specified transfer categories are excluded only when all four listed payment features remain unchanged. | Affiliate transfer; merger/acquisition of servicers or subservicers; or master-servicer transfer without changing subservicer. Required unchanged features: payee, payment-delivery address, account number, and payment amount. | S009 §33(b)(2)(i)(A)–(C). | R; unchanged features alone do not create an additional unlisted category. |\n| **R006-P1-C020** | FHA has a specific notice exception when a National Housing Act-insured mortgage is assigned to FHA. | Applies to FHA’s stated duty; it is not a blanket exemption for every participant or every FHA-insured loan. | S009 §33(b)(2)(ii). | R; distinguish from the servicer-definition exclusions. |\n| **R006-P1-C021** | Ordinary clocks are transferor ≥15 days before; transferee ≤15 days after; combined servicing notice ≥15 days before. | **Calendar days** under §31. The transferee deadline does not require waiting until after transfer. No weekend/holiday exclusion or extra mailing days is stated for these clocks. | S001 §2605(b)(2)(A), (c)(2)(A); S007 “Day”; S009 §33(b)(3)(i). | S/R; no actual calendar calculation made. |\n| **R006-P1-C022** | The specified distress events permit notice no later than 30 days after the effective date. | Transfer must be preceded by servicing-contract termination for cause, commencement of servicer bankruptcy, specified FDIC proceedings, or specified NCUA proceedings. Statutory text separately names FDIC/RTC. | S001 §2605(b)(2)(B), (c)(2)(B); S009 §33(b)(3)(ii). | S/R; anticipated distress or ordinary inconvenience is not the stated trigger. |\n| **R006-P1-C023** | Compliant transfer notices at settlement satisfy the regulation’s timing requirement. | Separate or combined transferor/transferee notices under §33(b)(3)(iii). Statutory closing language refers to the loan maker providing the specified written notice. | S001 §2605(b)(2)(C), (c)(2)(C); S009 §33(b)(3)(iii). | S/R; no automatic settlement exception under §1026.39. |\n| **R006-P1-C024** | Regulation X disclosures generally must be clear, conspicuous, written, and retainable. | Electronic delivery is conditioned on E-Sign consumer consent and other applicable requirements. Foreign-language disclosures must be available in English on request. Combination is permitted unless prohibited by applicable law or specified regulatory agreement. | S008 §32(a)–(b). | R; an email’s existence does not establish compliant electronic delivery. |\n| **R006-P1-C025** | For mailing under Regulation X, placing correctly addressed material in the mail can satisfy the mailing requirement whether or not received. | Use §11 and transfer comment 33(b)(3)-1: appropriate borrower address(es), including a qualifying notified change. A notice’s printed date alone does not prove dispatch. | S006 §11; S009 comment 33(b)(3)-1. | R/O; the last sentence is I. Actual **payment receipt** uses a different test. |\n| **R006-P1-C026** | The servicing notice must disclose the effective date and usable contacts for both servicers. | For each servicer, §33(b)(4)(ii)–(iii) specifies employee/department name, address, and toll-free or collect-call telephone number for transfer inquiries. Statutory subparagraphs separately identify the transferee and contacts. | S001 §2605(b)(3)(A)–(D), (c)(3); S009 §33(b)(4)(i)–(iii). | S/R; ownership identification is a separate regime. |\n| **R006-P1-C027** | Remaining required servicing content concerns acceptance dates, optional insurance, and unchanged nonservicing terms. | Old stop/new start acceptance dates must be the same or consecutive days; disclose optional-insurance effects and necessary preservation actions; state transfer does not affect terms other than directly servicing-related terms. | S001 §2605(b)(3)(E)–(G); S009 §33(b)(4)(iv)–(vi). | S/R; statutory wording concerns security instruments; regulation refers to mortgage-loan terms. |\n| **R006-P1-C028** | Current MS-2 also includes a payment-address instruction and a 60-day protection paragraph. | Those model passages must be distinguished from §33(b)(4)’s enumerated content. The final-rule explanation retained them without making every model sentence an independent enumerated requirement. | S010 MS-2; S017 pp.10732, 10839; S011 pp.752–753. | R/H; omission is not automatically classified solely by model comparison. Operative “beginning” controls over the model’s “following” wording. |\n| **R006-P1-C029** | MS-2 is optional; appropriate use has the stated disclosure-compliance protection. | Required information still must be supplied. Permissible changes must preserve substance, clarity, and meaningful sequence; inapplicable content may be removed. Successor wording may avoid implying personal liability. | S010/S011 Appendix MS comments 1–2, including 2(iv)(A)–(C). | O; no actual notice compliance or broader immunity found. |\n| **R006-P1-C030** | The application-stage servicing disclosure is separate from an actual transfer notice. | Current §33(a) applies to reverse-mortgage applications; its three-day period excludes legal public holidays, Saturdays, and Sundays; timely denial is an exception. Section 2’s general business-day definition is not substituted for this express exclusion. | S009 §33(a), comments 1–3; S007 §30(c)(1); S004 “Business day.” | R/O; MS-1 and MS-2 serve different events. |\n| **R006-P1-C031** | The preemption provisions concern the specified notice requirements; they do not resolve all state-law issues. | §2605(h), §33(d), and §5(c) must be read together. Section 33(d) preserves specified notices to insurance companies or taxing authorities. | S001 §2605(h); S005 §5(c); S009 §33(d). | S/R/O; state title, assignment, contract, and other law remain held. |\n\n### C. Transition payments and proof boundaries\n\n| Claim ID | Area and precise claim | Trigger, conditions, and exceptions | Source pinpoint | Status / limit |\n| --- | --- | --- | --- | --- |\n| **R006-P1-C032** | The protection concerns a payment received by the transferor during the **60-day period beginning on the servicing effective date**. | Statute says receipt **before** the applicable due date; regulation says **on or before**, including a grace period allowed by the loan instruments. Apply the regulation’s actual wording rather than silently paraphrasing the two texts as identical. | S001 §2605(d); S009 §33(c)(1); S011 §33. | S/R; begins with the transfer event, not notice receipt. |\n| **R006-P1-C033** | A qualifying payment may not be treated as late for any purpose; late fees are included. | This does not establish an account-wide credit-reporting freeze, protection for unrelated unpaid installments, or general immunity. Comment 33(c)(1)-2 says compliance with §1024.39 during the period is not itself prohibited late treatment. | S009 comments 33(c)(1)-1–2; S001 §2605(d), distinguished from (e)(3). | S/R/O; broader reporting/remedies questions held. |\n| **R006-P1-C034** | Beginning on the effective date, the old servicer must promptly forward an incorrectly received payment or return it and notify the payor of the proper recipient. | Forwarding must be to the transferee for account application. Return must be to the person who paid, with the recipient notification. The clause states **no numerical “promptly” deadline, no express 60-day end, and no specified written form for that notification**. | S009 §33(c)(2)(i)–(ii); S017 p.10733. | R/H; do not invent a forward-only duty or fixed number of days. |\n| **R006-P1-C035** | Inclusion of an instrument-authorized grace period in this protection does not itself amend the contractual due date, principal, rate, or amount. | Official delinquency commentary distinguishes a due-and-unpaid installment from a later late-fee assessment date. The transfer provision controls the specified treatment of qualifying misdirected payments. | S007 Delinquency comment 1; S009 §33(b)(4)(vi), (c)(1). | O/R plus I; actual contract and accrual remain held. |\n| **R006-P1-C036** | Sending, scheduling, or postmarking a payment is not the same factual proposition as old-servicer receipt. | Relevant predicates include actual recipient and receipt time, transfer effective date, applicable due/grace terms, and which payment the receipt concerns. | S009 §33(c)(1)–(2). | I from the receipt wording; unknown receipt stays U. |\n| **R006-P1-C037** | A partial payment must not be treated as proof that a full installment was satisfied. | Do not categorically erase the misdirection protection merely because a payment was partial; separately determine what was received and what remained unpaid. The payment-tolerance comment applies if the servicer elects the specified treatment. | S007 §31 “Delinquency,” comments 1–3; S009 §33(c); S014 §39(d)(5). | I/O; allocation, sufficient-payment treatment, and actual shortfall remain U/held. |\n\n### D. Ownership-transfer coverage, timing, content, exceptions, and delivery\n\n| Claim ID | Area and precise claim | Trigger, conditions, and exceptions | Source pinpoint | Status / limit |\n| --- | --- | --- | --- | --- |\n| **R006-P1-C038** | Section 1641(g) requires the new owner/assignee to give a written ownership-transfer notice within its stated 30-day period. | Statutory mortgage definition: consumer credit secured by the consumer’s principal dwelling. Content: new creditor identity/contact, transfer date, authorized contact, recording location, and relevant additional information. | S003 §1641(g)(1)–(2). | S; separate from servicing notice. |\n| **R006-P1-C039** | Current §39’s closed-end coverage is broader than the statute’s stated principal-dwelling definition. | Open-end: principal dwelling. Closed-end: **dwelling or real property**. Posted comment 39(a)(2)-1 still describes principal-dwelling coverage; amended text, comment 39(d)-2, and the final amendment establish the broader closed-end wording. | S014 §39(a)(2), comments 39(a)(2)-1 and 39(d)-2; S018 p.80130; S016. | R/O/H; discrepancy disclosed, not silently reconciled by narrowing the rule. |\n| **R006-P1-C040** | Consumer, dwelling, and person are distinct definitions. | Consumer credit is primarily personal/family/household. A dwelling can be a qualifying residential structure without real-property status. A covered owner can be an organization; an organizational purchaser does not thereby turn the borrower’s loan into organizational credit. | S013 §2(a)(11), (12), (19), (22), comments. | R/O; last sentence I. |\n| **R006-P1-C041** | Business-purpose and organizational-credit exclusions require the correct borrower/transaction analysis. | Section 3(a) applies; necessary trust interpretations prevent treating every trust transaction as automatically excluded. | S013 §3(a)(1)–(2), relevant comments; §2(a)(11) comments. | R/O; no actual consumer/business or trust determination. |\n| **R006-P1-C042** | A §39 covered person acquires legal title to an existing mortgage debt and acquires **more than one mortgage loan in any twelve-month period**. | Purchase, assignment, or other transfer can qualify; the person need not satisfy Regulation Z’s separate “creditor” definition. Partial and joint legal-title acquisitions can qualify. | S014 §39(a)(1), comments 1–2. | R/O; acquisition frequency and actual legal title are not presumed. |\n| **R006-P1-C043** | Beneficial interest, a security interest, or credit risk without legal title does not satisfy the legal-title trigger. | Administrative-convenience assignment to a servicer is also excluded as specified. | S003 §1641(f)(1)–(3); S014 §39(a)(1), comment 3. | S/R/O; securitization or servicing labels alone do not decide the issue. |\n| **R006-P1-C044** | Affiliation does not itself excuse an ownership disclosure. | Acquisition by a separate legal entity, including through a qualifying merger, acquisition, or reorganization, is addressed by the ownership rule, subject to its other conditions. | S014 comments 39(a)(1)-2(iii), -4. | O; do not import the Regulation X affiliate exception. |\n| **R006-P1-C045** | The owner must mail or deliver by the **30th calendar day following** its defined transfer date. | The covered person may use acquisition recognized in its books or transfer recognized in the transferor’s books. No business-day exclusion, holiday extension, or extra presumed receipt period is stated here. | S014 §39(b), (b)(2); S016. | R; notice date or recording date is not freely substituted. |\n| **R006-P1-C046** | Ownership disclosures must be clear, conspicuous, written, and retainable; electronic provision is E-Sign-conditioned. | With multiple liable consumers, delivery to any primarily liable consumer is permitted by §39(b)(3). Combining with servicing notices is allowed only if applicable requirements are met. | S014 §39(b)(1), (3), comment 39(b)(1)-1. | R/O; do not import this recipient rule into §33. |\n| **R006-P1-C047** | Disposition of **all** acquired interest by the 30th calendar day can exempt that intermediate acquirer. | Retention of a partial interest on that day prevents reliance on this particular exception. The next acquirer requires its own analysis. | S014 §39(c)(1), comments 1–2. | R/O; no chain-wide exemption. |\n| **R006-P1-C048** | A qualifying repurchase agreement can excuse disclosure while its specified arrangement applies. | The transferor must be obligated to repurchase. If repurchase does not occur, the covered person must disclose within 30 days after recognizing acquisition on its books; the interpretation also addresses intermediaries. | S014 §39(c)(2), comment 1. | R/O; not every temporary holding or warehouse arrangement qualifies. |\n| **R006-P1-C049** | The partial-interest exception requires both a partial acquisition and no specified authorized-contact change. | The party authorized to receive rescission notice and resolve payment issues must remain unchanged as a result of the transfer. Same servicer alone does not establish the exception; acquisition of the remaining interest is separately addressed by the comment. | S014 §39(c)(3), comments 1–2. | R/O; no general “same servicer” exemption. |\n| **R006-P1-C050** | For sequential acquisitions, one disclosure for multiple covered persons is optional if each person’s requirements are met. | Each retains its compliance duty. A subsequent transfer date may be estimated only under the comment’s unknown/reasonably-available, good-faith diligence standard. | S014 §39(b)(4), comments 1–3. | R/O; no invented actual dates. |\n| **R006-P1-C051** | Joint acquisition requires a single disclosure for the joint covered persons. | Where completion dates differ, the comment uses the earliest acquisition’s clock. Separate, unrelated partial acquisitions are different: each duty remains, although a compliant combined disclosure is possible. | S014 §39(b)(5), comments 1–4; 39(a)(1)-2(ii). | R/O; “multiple owners” does not by itself establish joint acquisition. |\n| **R006-P1-C052** | The notice must identify the transferred loan and provide the covered owner’s name, address, telephone number, and transfer date. | Loan identification must be sufficient under the comment; no actual or invented identifying value is entered here. Servicer contact alone is not ordinarily a substitute for owner identification. | S014 §39(d), (d)(1)–(2), comments 39(d)-1 and 39(d)(1)-1. | R/O. |\n| **R006-P1-C053** | A combined notice ordinarily identifies each covered person; a narrow authorized-owner exception can permit identification of only one. | The identified party must itself be a covered person authorized for both specified rescission and payment functions. | S014 §39(d)(1)(i)–(ii), corresponding comments. | R/O; identifying any servicing agent is not equivalent. |\n| **R006-P1-C054** | The authorized-contact disclosure concerns receiving rescission notices and resolving payment issues. | Owner contact can suffice if usable for those purposes. If multiple agents are listed, their differing authority must be explained. No new agent need be appointed; email/website are optional. | S014 §39(d)(3), comments 1–2. | R/O; this content requirement does not create an otherwise absent rescission right. |\n| **R006-P1-C055** | The recording disclosure permits the stated alternatives. | Disclose where ownership transfer is or may be recorded, or truthfully that it has not been recorded when notice is provided. The comment does not require an exact street address. | S014 §39(d)(4), comment 1. | R/O; neither recording nor validity is established by the notice’s assertion. |\n| **R006-P1-C056** | Applicable closed-end notices must disclose the partial-payment policy under the specified heading. | Excludes reverse mortgages from this **additional content**, not automatically the entire ownership rule. State the applicable accept/apply, accept/hold-until-complete, or reject policy; include that a later lender may have a different policy. | S014 §39(d) introductory text, (d)(5)(i)–(iv); S018 p.80130. | R; a policy disclosure is not an adjudication of lawful payment application. |\n| **R006-P1-C057** | Old application dates do not create a perpetual exclusion from §39(d)(5). | The official implementation commentary addresses October 3, 2015 transition treatment and conditions occurring on or after **October 1, 2018**, regardless of application date. | S015 comment 1(d)(5)-1, especially post-consummation provisions. | O; no individual deadline calculated. |\n| **R006-P1-C058** | Regulation Z includes confirmed-successor treatment and a specified notice/acknowledgment limitation. | Apply §2(a)(11), (27) and §39(f)’s actual wording, including the compliant Regulation X notice, nonliability, assumption, acknowledgment, and revocation conditions. | S013 relevant successor definitions/comments; S014 §39(f); S019 instruction 22. | R/O; not a general owner exemption or determination of personal liability. |\n| **R006-P1-C059** | Transmission on another covered person’s behalf is contemplated; substantive responsibility is not erased. | Current multiple-person provisions expressly allocate duties; the 2013 explanation contemplates owner/servicer arrangements for required disclosure. A sender’s letterhead alone proves neither ownership nor authority nor compliance. | S014 §39(b)(4)–(5), duty comments; S018 pp.80059–80060. | R/O; broader agent-delivery conclusion is bounded I. Actual agency is U. |\n| **R006-P1-C060** | A contact change alone, without qualifying acquisition, is not the §39 ownership-transfer trigger. | Conversely, a qualifying partial transfer plus change of the specified authorized party can defeat §39(c)(3)’s exception. Other contact-update duties are outside this component. | S014 §39(a), (c)(3), (d)(3), (e). | I from the stated trigger; no general exemption from other law. |\n| **R006-P1-C061** | These disclosure provisions do not make a notice conclusive proof of assignment, title, security rights, balance, or standing. | Likewise, absence or defect of notice does not itself establish invalid assignment, debt cancellation, or a remedy. Distinct substantive and evidentiary law would be needed. | S001 §2605(b)–(d); S003 §1641(g); S014 §39(a), (d). | Expressly bounded I; all actual legal-status and litigation questions held. |\n\n### E. Versions, history, and unresolved source issues\n\n| Claim ID | Precise claim | Source pinpoint | Status / limit |\n| --- | --- | --- | --- |\n| **R006-P1-C062** | Current MS-2 retains the short payment-transition protection paragraph. Historical complaint-resolution/QWR language and proposals discussed in the 2013 preamble are not imported as current required transfer-notice content. | S010–S012; S017 pp.10730–10733, 10839. | H/R/O; current text controls; no historical full-form reconstruction claimed. |\n| **R006-P1-C063** | Agency “current” labels and House compilation dates do not establish a complete through-today legal audit. Direct eCFR and 2026 annual §39 body gaps remain. | S001–S003, S016, S022–S024. | U as to exhaustive currency; substantive retrieved text identified precisely. |\n| **R006-P1-C064** | Relevant implementation dates are separate from access dates: §1641(g)’s May 20, 2009 statutory event; 2013 servicing rule’s January 10, 2014 effective date; successor provisions’ April 19, 2018 effective date; partial-payment transition in C057. | S003, S015, S017, S019–S020. | S/H/O. The 2010 former-rule effective-date discrepancy is not resolved or used to decide a historical transaction. |\n| **R006-P1-C065** | The posted §31 page’s COVID definition is stale relative to the 2025 removal and 2026 annual CFR. The relevant day, servicing, mortgage-loan, and successor definitions were separately checked. | S007; S011 §§30–31; S021 instruction 2. | R/H; this finding does not reopen COVID servicing or foreclosure law. |\n| **R006-P1-C066** | No actual transfer date, receipt date, contractual payment deadline, amount, or individual compliance result has been established. | Assignment limits; C013, C021–C023, C032, C045. | U by design. All periods remain event-triggered; no actual-calendar arithmetic performed. |\n\n**Additional text-quality observation:** comment 39(d)(5)-1 refers to paragraph **(iii)** when describing the statement that a later lender may have a different policy; the operative statement is in **(iv)**. The operative numbering was used above. This is a source-text discrepancy, not permission to rewrite the rule. [Consumer Financial Protection Bureau](https://www.consumerfinance.gov/rules-policy/regulations/1026/39/?utm_source=chatgpt.com)\n\n## 4. What the payment protection does—and what must be proved\n\nThe relevant test can be stated without assigning a date or entering an account identifier:\n\n**Covered servicing transfer + receipt by the transferor during the 60-day period beginning on its effective date + receipt on or before the applicable due date, including an instrument-authorized grace period = the specified protection against treating that payment as late.**\n\nThis is a statement of conditions, not a finding that they occurred. C032–C037 supply the authorities and limits.\n\n| Proposition to establish | Necessary evidence category, described generically | What does not establish it by itself |\n| --- | --- | --- |\n| Applicable loan and actor coverage | Product, purpose, collateral/nexus, servicing-role facts, and any claimed exception | “Mortgage,” “secured,” “bank,” “small servicer,” or “business” as an unexplained label |\n| Servicing effective date | The event satisfying §2605(i)(1), or the reverse-mortgage agreed-date rule | Ownership sale date, recording date, notice date, or date the borrower learned of the transfer |\n| Receipt by the old servicer | Evidence of actual receipt by that recipient and when it occurred | Mailing a check, scheduling bill pay, an instruction to an intermediary, or an unsupported assertion of receipt |\n| Applicable payment deadline | Relevant due-date and grace-period provisions of the governing instruments | A general expectation that all loans have the same grace period |\n| Which payment was received | Sufficient reconciliation of the receipt to the payment obligation and amount tendered | Assuming every receipt paid the entire installment or cured earlier arrears |\n| Prohibited late treatment | The actual fee or classification, its basis, and its relationship to the qualifying payment | The mere existence of a transfer, account delinquency, or a later communication |\n| Compliance with forwarding/return | Receipt chronology, onward transfer or return, and recipient notification where returned | A notice saying the old servicer will stop accepting payments |\n| Notice timeliness | Actual mailing/delivery evidence, proper address/method, and the correct event clock | Only the date printed on the notice or the consumer’s nonreceipt |\n\nThese are **proof categories only**. No actual records are requested, searched, evaluated, or presumed.\n\nA grace period can matter to §33(c)(1)’s specific test without moving the underlying contractual due date. A payment returned under §33(c)(2) is also not the same event as application to the account. The provision requires prompt handling and notification as stated; it does not supply a complete account-crediting, shortfall, or default determination. [Consumer Financial Protection Bureau+1](https://www.consumerfinance.gov/rules-policy/regulations/1024/33/?utm_source=chatgpt.com)\n\n## 5. Clearly hypothetical qualitative failure branches\n\nEvery row below is hypothetical. The rows use roles and qualitative facts only; no real or fictional person, provider, property, account, or case identifiers are supplied.\n\n| Example | Stipulated hypothetical facts | Statute/regime-specific result versus unknown | Evidence category needed to resolve the unknown—not a records request | Adverse misclassification to avoid |\n| --- | --- | --- | --- | --- |\n| **E01 — Servicing only** | A covered loan’s servicing transfers; debt ownership remains unchanged; no transfer exception is stipulated. | Analyze both §33 notices and payment-transition rules. An ownership notice is not triggered merely by that stipulated servicing event. C018–C037, C042. | Actual servicing effective date, dispatch/content, exception facts, and payment receipt if relevant. | Treating the new servicer as necessarily the new debt owner. |\n| **E02 — Ownership only, same servicer** | A qualifying covered person acquires full legal title; the existing servicer continues; no ownership exception applies. | §39 disclosure is implicated despite unchanged servicing. The acquisition alone does not start §33’s servicing-transfer protection. C038–C049. | Acquisition recognition, covered-person frequency, and notice dispatch/content. | Assuming “same servicer” eliminates ownership disclosure. |\n| **E03 — Both transfers; one late combined letter** | Both events occur; the only combined letter is sent after the servicing effective date; no special servicing timing exception is stipulated. | That timing cannot satisfy the ordinary **combined servicing notice** requirement. Ownership timing/content require their own analysis; a timely ownership disclosure does not cure the servicing timing problem. C021–C023, C045–C046. | Separate event clocks, actual dispatch, and full content. | Treating one envelope as automatic satisfaction of both regimes. |\n| **E04 — Claimed timely old-servicer receipt** | The payer asserts that the former servicer received the payment within the protected period and by the applicable deadline; receipt is not independently stipulated. | Protection is conditional; the assertion alone leaves the receipt predicate unknown. If established, C032–C033 supply the treatment rule. | Actual receipt time/recipient, instrument deadline/grace, and treatment of that payment. | Declaring a prohibited late fee solely from the payer’s claim. |\n| **E05 — Sent, receipt unknown** | Payment was sent toward the old servicer; actual recipient and receipt date are unknown. | Sending does not establish §33(c)(1). Section 33(c)(2)’s handling duty likewise depends on receipt by the transferor. C034, C036. | Delivery/receipt chronology and any return. | Replacing receipt with postmark, scheduling date, or intent. |\n| **E06 — Partial payment** | The old servicer receives less than the full installment within the relevant period and deadline. | Do not assume full satisfaction; do not categorically disregard the misdirection protection. Treatment of the received payment and any unpaid remainder are separate questions. C037, C056. | Amount received relative to the installment, tolerance treatment, applicable policy, and application/return facts. | Calling a short installment fully cured, or denying all protection merely because it was partial. |\n| **E07 — Product branch unresolved** | The product might be an open-end home-equity plan, consumer closed-end mortgage, or primarily business-purpose credit; classification is not stipulated. | Coverage is unresolved. A principal-dwelling HELOC is excluded by Regulation X Subpart C’s definition but can fall within §39’s ownership definition. No broader statutory-claim decision follows here. C004, C008, C039–C041. | Product structure, purpose, security, federal nexus where required. | Applying one mortgage regime to every secured product. |\n| **E08 — Subservicing branch unresolved** | A servicing arrangement changes, but the master/subservicer functions and changes in the four payment features are unknown. | No automatic exemption or duty finding. Test the actual §33(b)(2)(i) category and every condition. C012, C019. | Functions transferred; qualifying affiliation/merger/master relationship; four payment features. | Assuming every subservicer change is exempt—or every internal change necessarily triggers notice. |\n| **E09 — Sequential ownership transfers** | An intermediate covered acquirer disposes of all its interest within the stated 30-day exception period. | That acquirer may use §39(c)(1); the next acquirer needs its own analysis. If the intermediate retains an interest, the stated exception does not follow. C047, C050. | All-interest disposition, recognition dates, retained interest, and subsequent acquirer’s conditions. | Extending one intermediary’s exception through the whole chain. |\n| **E10 — Joint owners and agent delivery** | Multiple covered persons jointly acquire; an authorized sender transmits one disclosure on their behalf. | Joint-acquisition single-notice and earliest-clock rules apply. Owner identification and the narrow authorized-owner exception still matter; sender identity does not erase duties. C051–C054, C059. | Joint agreement character, dates, owners identified, scope of authorization, dispatch/content. | Equating the agent with the owner or using the latest acquisition date automatically. |\n| **E11 — Contact change alone** | The debt owner and servicer remain the same; only contact details change; no acquisition occurs. | The stipulated change alone is not §39’s acquisition trigger. Other contact-update rules remain held. A partial acquisition plus authorized-party change would be a different branch. C049, C060. | Whether an acquisition actually occurred and what authority changed. | Treating every address change as ownership transfer, or treating contact changes as irrelevant to the partial-interest exception. |\n| **E12 — Confirmed property successor** | A qualifying property successor is confirmed but has not assumed personal liability. | Borrower/consumer treatment and the precise acknowledgment provisions apply. Property succession is not acquisition of the creditor’s debt. C014–C017, C058. | Qualifying succession, confirmation, liability status, compliant notice/acknowledgment, and any revocation. | Converting receipt of notices into debt assumption or creditor ownership. |\n| **E13 — Receipt outside the 60-day window** | The old servicer incorrectly receives a payment after the protected 60-day period. | Section 33(c)(1)’s period cannot simply be extended. Section 33(c)(2) has no express 60-day cutoff and still requires its own handling analysis. C032, C034. | Actual effective date, receipt, forwarding/return chronology, and notification. | Ending every transfer-related handling duty at day 60. |\n| **E14 — Claimed emergency or settlement exception** | A party invokes “emergency transfer” or says “notice was handled at closing,” without the qualifying facts stipulated. | The label does not establish the specified timing exception. Ownership notice timing remains separate. C022–C023, C045. | Enumerated preceding event or compliant settlement notices, plus dispatch/content. | Turning a narrow timing exception into a blanket notice exemption. |\n\n## 6. Blank generic notice-audit worksheet\n\nThis is an **uncompleted analytical worksheet**, not a notice, demand, filing, or request for records. Leave all responses blank. Do not enter identifiers.\n\n| Audit item | Blank response | Governing reference |\n| --- | --- | --- |\n| Consumer/open-end/closed-end/reverse product classification established? | ________ | C003–C008, C039–C041 |\n| Necessary purpose and collateral conditions established? | ________ | C002–C006, C040–C041 |\n| Regulation X federal nexus established where required? | ________ | C002–C003 |\n| Statutory/regulatory actor exclusions considered separately? | ________ | C009–C011 |\n| Servicing transfer, debt-title transfer, property succession, or more than one event? | ________ | C001, C012–C015, C042 |\n| Master/subservicer functions distinguished? | ________ | C012 |\n| Exact conditional transfer exclusion identified, if any? | ________ | C019–C020 |\n| All four unchanged-payment conditions tested where required? | ________ | C019 |\n| Servicing effective-date basis identified, without entering a date? | ________ | C013 |\n| Transferor, transferee, separate, or combined servicing notice? | ________ | C018, C021 |\n| Ordinary, specified extended, or settlement timing branch? | ________ | C021–C023 |\n| Mailing/delivery act distinguished from printed date and receipt? | ________ | C024–C025 |\n| Correct address(es)/change-of-address rule tested? | ________ | C025 |\n| Effective date and both required servicing contacts disclosed? | ________ | C026 |\n| Stop/start payment acceptance dates compatible? | ________ | C027 |\n| Optional-insurance effects/actions addressed as applicable? | ________ | C027 |\n| Required nonservicing-terms statement present? | ________ | C027 |\n| Model-only language distinguished from enumerated requirements? | ________ | C028–C030 |\n| Actual old-servicer payment receipt established? | ________ | C032, C036 |\n| Applicable due/grace terms and 60-day window distinguished? | ________ | C032, C035 |\n| Full/partial payment and remaining shortfall kept separate? | ________ | C037 |\n| Prompt forwarding or return-plus-notification analyzed? | ________ | C034 |\n| Ownership covered-person legal-title/frequency conditions established? | ________ | C042–C044 |\n| Ownership transfer-date recognition basis identified? | ________ | C045 |\n| Each ownership exception tested on all conditions? | ________ | C047–C049 |\n| Sequential versus joint acquisitions distinguished? | ________ | C050–C051 |\n| Loan sufficiently identified, without copying any identifying value here? | ________ | C052 |\n| Owner identification and any narrow multiple-owner exception tested? | ________ | C052–C053 |\n| Agent functions and differing authority explained? | ________ | C054, C059 |\n| Recording disclosure matches an allowed, truthful alternative? | ________ | C055 |\n| Applicable partial-payment policy content included? | ________ | C056–C057 |\n| Confirmed-successor/acknowledgment provisions relevant and satisfied? | ________ | C014–C017, C058 |\n| Combined document separately satisfies each applicable regime? | ________ | C021, C024, C046 |\n| Notice conclusions kept separate from assignment/title/balance/standing conclusions? | ________ | C061 |\n| Unresolved facts and source-currentness/image gaps explicitly retained? | ________ | C063, C065–C066 |\n\n## 7. Granular coverage table\n\n**Status:** **A** = generic legal question answered; **P** = answered with a specified source limitation; **U** = factual branch unresolved by design; **X** = excluded by the assignment.\n\n“Next permissible step” means a bounded **public-authority** investigation. It does not authorize actual-record searches or requests.\n\n| Assigned subquestion / major branch | Status | Claim / example links | Exact missing authority or facts | Next bounded permissible investigation |\n| --- | --- | --- | --- | --- |\n| §2605(b) transferor duty/content | A | C018, C021–C027 | Actual coverage/event/notice facts absent | None needed for the stated generic rule |\n| §2605(c) transferee duty/content | A | C018, C021–C027 | Same | Same |\n| §2605(d) payment protection | A/U | C032–C037; E04–E06 | Actual receipt, deadline, payment and treatment facts | None without changing the no-record scope |\n| Statutory FRML definition | A | C002 | Actual collateral/nexus | Further generic definition authority only if a new product question is authorized |\n| §2606 purpose/government exclusions | A/U | C004 | Actual purpose and recipient category | No factual classification undertaken |\n| §1024.2 necessary definitions | A | C003, C009–C013 | Actual role and product facts | None for stated branches |\n| Temporary/construction/bridge exclusions | A/U | C005 | Financing structure, term, builder/permanent-finance conditions | No actual-product investigation |\n| Vacant-land exclusion and exception | A/U | C006 | Use of proceeds and construction/placement conditions | Same |\n| Assumption and conversion exclusions | A/U | C006 | Approval right/permission; original terms/new note | Contract work held |\n| Secondary-market carveback | A | C007 | Actual transaction character | None for the statutory/regulatory distinction |\n| Partial exemptions under §5(d) | A | C007 | Whether a specific transaction meets them | No general TRID gateway rerun |\n| §30 small-servicer/reverse/qualified-lender limits | A | C008; E07 | Actual exemption status not determined | None needed to show these are not blanket §33 exemptions |\n| Principal residence versus broader §33 scope | A | C008 | Actual product/property facts | No property investigation |\n| Open-end product divergence | A/P | C008, C039; E07 | Any broader direct statutory-claim issue is not adjudicated | If later authorized, examine public authority on that precise statutory/regulatory issue |\n| Servicer versus master/subservicer | A/U | C009, C012, C019; E08 | Actual functions/agreement and payment changes | Generic authority only; no provider investigation |\n| Statutory and regulatory named-actor exclusions | A/U | C010–C011 | Applicable actor/function/distress facts | No entity-status query |\n| Confirmed successor definition | A/U | C014–C015; E12 | Qualifying transfer and confirmation | No property/identity investigation |\n| Successor acknowledgment exceptions | A/U | C016–C017, C058; E12 | Compliance, assumption, acknowledgment/revocation facts | None for generic conditions |\n| Both servicers’ duties | A | C018; E01 | Actual notice performance | No records work |\n| Affiliate/merger/master exclusions | A/U | C019; E08 | Listed category and all four unchanged features | No corporate investigation |\n| FHA-specific notice exception | A/U | C020 | Exact assignment/actor facts | No loan/provider investigation |\n| Separate and combined servicing clocks | A | C021; E03 | Actual event and dispatch dates | Keep triggered periods; no calendar invented |\n| Extended timing events | A/U | C022; E14 | Enumerated preceding event | No bankruptcy/corporate/docket query |\n| Settlement timing | A/U | C023; E14 | Compliant settlement notice facts | No closing-document request |\n| Mailing versus receipt | A/U | C024–C025; E04–E05 | Actual dispatch, addresses, electronic conditions | No evidence collection |\n| Business/calendar-day distinctions | A | C021, C030, C045 | No dates supplied | No arithmetic needed |\n| Required payment/contact/address/effective-date content | A | C026–C028 | Actual document text absent | Blank audit supplied |\n| Current MS-2 complete text | A | C028–C029, C062 | None as to parsed model text | None needed for text identification |\n| MS-2 pixel/layout inspection | P | S011–S012; failure log | Inspectable image content was not exposed by screenshot responses | Obtain inspectable images of only the two official model pages through an authorized public-web capability |\n| Historical/proposed model distinction | A/P | C030, C062 | No complete historical form reconstruction attempted | Only if a historical-version question becomes necessary |\n| 60-day trigger versus notice date | A | C013, C032 | Actual effective date | No actual calculation |\n| Late-fee/late-treatment restriction | A/U | C033 | Particular fee/classification and payment linkage | Full reporting/remedy work held |\n| Forwarding/return and recipient notification | A/U | C034; E13 | Receipt/handling/notification facts; contextual promptness | Generic authority on “promptly” only if a later narrow question requires it |\n| Grace period versus contract modification | A/U | C035 | Actual contractual terms | Contract analysis held |\n| Sent-but-unreceived payment | A/U | C036; E05 | Receipt unknown | Retain unknown |\n| Partial payment | A/U | C037; E06 | Shortfall, policy, tolerance, application | Full payment-crediting/accounting analysis held |\n| §1641(g) statute and §39 product difference | A | C038–C041 | No actual product facts | None for text comparison |\n| Posted §39 scope-comment inconsistency | A/P | C039 | Complete publisher correction history not audited | Check official correction/amendment publications if needed |\n| Covered person/legal-title/frequency | A/U | C042 | Actual title acquisition and acquisition frequency | No owner/entity/loan roster investigation |\n| Beneficial/security interest and administrative convenience | A/U | C043 | Actual interest acquired and purpose | Assignment/title work held |\n| Ownership affiliate/merger branch | A/U | C044 | Different-entity acquisition facts | No corporate-record query |\n| Ownership timing and date election | A/U | C045 | Recognized acquisition/transfer date | No books-and-records request |\n| Ownership recipient/form/combination | A/U | C046 | Actual liable-recipient and delivery facts | No individualized compliance finding |\n| All-interest disposition exception | A/U | C047; E09 | Retained/disposed interest and timing | No chain-of-title investigation |\n| Repurchase exception | A/U | C048 | Repurchase obligation and recognition facts | Generic contract-law expansion held |\n| Partial-interest/no-contact-change exception | A/U | C049; E11 | Interest and authorized-party changes | No provider/agency investigation |\n| Sequential transfers | A/U | C050; E09 | Sequence, timing, availability of future-date information | No record search |\n| Joint acquisitions | A/U | C051; E10 | Same agreement/concert, completion dates | No transaction-record search |\n| Owner/agent/recording content | A/U | C052–C055, C059 | Actual notice, agency authority, recording facts | No recording search or identifiers |\n| Partial-payment disclosure and transition dates | A | C056–C057 | Actual applicable policy unknown | No full payment-processing review |\n| Contact change without acquisition | A | C060; E11 | Stipulated in example; actual event unknown | Other update duties held |\n| Notice versus assignment/security/standing proof | A/X | C001, C061 | Substantive documents and applicable law intentionally absent | Parent-held investigation; not authorized here |\n| Full current-law/session-law lag audit | P | C063–C065; S023–S024 | Direct eCFR bodies; verified 2026 annual §39; complete post-compilation update audit | Retrieve official current bodies and bounded amendment/correction history |\n| Hypothetical branches | A | E01–E14 | No individual facts intended | None |\n| Blank audit worksheet | A | Section 6 | All entries deliberately blank | None |\n| Cases/opinions | X | Read log | No material opinion necessary for this text-focused component | Published majority opinion only if a later narrow legal issue strictly requires it |\n| State/local/tribal/foreign/product/contract closure | X | C031, C061; parent holds | All jurisdictional and actual-contract predicates absent | Separate authorization and bounded scope required |\n| Eligibility, liability, remedies, litigation decision | X | C061, C066 | Not investigated or decided | Remains parent-held |\n\n## 8. Read and failure log\n\n| Log item | What actually happened | Effect on the report |\n| --- | --- | --- |\n| **F01 — Initial House routes failed** | Legacy routes, including [https://uscode.house.gov/view.xhtml?req=granuleid:USC-prelim-title12-section2605&num=0&edition=prelim](https://uscode.house.gov/view.xhtml?req=granuleid:USC-prelim-title12-section2605&num=0&edition=prelim) and [https://uscode.house.gov/view.xhtml?req=granuleid:USC-prelim-title15-section1641&num=0&edition=prelim](https://uscode.house.gov/view.xhtml?req=granuleid:USC-prelim-title15-section1641&num=0&edition=prelim), failed. New publisher routes in S001–S003 subsequently supplied the necessary bodies. | **Recovered**, with exact compilation dates preserved. Earlier failures are not evidence of missing statutes. |\n| **F02 — Direct eCFR failed** | The four section URLs in S023 did not yield operative bodies. | **Unresolved retrieval gap**, mitigated by annual CFR, agency text, and final-rule reads. |\n| **F03 — Annual Regulation Z edition** | The 2026 §39 URL in S024 failed; the most-recent link returned the 2025 edition. | No claim that the 2026 edition does not exist; no claim that 2025 alone proves current law. |\n| **F04 — Model retrieval boundaries** | A one-page appendix granule was initially available. Full-part retrieval supplied the continuation, so complete MS-2 text was read. The 2026 model is at pp.752–753, not the 2025 pp.754–755. | No claim that an isolated first page was the full notice. |\n| **F05 — Screenshot limitation** | One earlier screenshot timed out; later requests reported image-display markers. Inspection of the returned structure showed text markers without image blocks available for visual review. | **Parsed text is not pixels.** No unseen full-form or layout claim is made. |\n| **F06 — Other recovered routes** | Capitalized CFPB model URL failed; the actual lowercase /ms2/ route worked. An attempted 2013 TRID PDF route failed; official GovInfo HTML supplied the necessary full clauses and printed-page markers. | Recovered text reads; no claim to have inspected the failed PDF’s images. |\n| **F07 — Agency “current” discrepancy** | The §31 agency page retains a definition removed by the July 15, 2025 rule; the 2026 CFR reflects removal. | The stale definition was not used. This is concrete evidence that a current-page label is not a complete currency audit. |\n| **F08 — Regulation Z discrepancies** | Posted scope comment is narrower than amended closed-end text; partial-payment comment has the paragraph-reference mismatch described above. | Operative clauses and final amendment used; inconsistencies disclosed. |\n| **F09 — Historical effective-date discrepancy** | S020’s front matter and §VI state different effective dates for the 2010 former rule while agreeing on mandatory compliance. | No historical transaction result is based on choosing one silently. |\n| **F10 — Search discoveries not treated as law** | Searches surfaced proposed and unrelated material, including the 2024 proposed servicing changes at [https://www.federalregister.gov/documents/2024/07/24/2024-15475/streamlining-mortgage-servicing-for-borrowers-experiencing-payment-difficulties-regulation-x](https://www.federalregister.gov/documents/2024/07/24/2024-15475/streamlining-mortgage-servicing-for-borrowers-experiencing-payment-difficulties-regulation-x?utm_source=chatgpt.com). Its operative body was not used. | Discovery only; no proposed rule applied as current law. |\n| **F11 — Guidance status** | No CFPB circular, bulletin, or advisory supplied a substantive rule in this report. | The user’s withdrawn-guidance cross-check condition was not triggered. No withdrawal is equated with statutory repeal. |\n| **F12 — Opinions and case records** | No majority opinion was necessary or relied upon. Case references appearing inside a preamble were not treated as opinions read. No actual case record, docket, or status query occurred. | No holding, disposition, later-history, standing, or remedy claim is made. |\n| **F13 — Read extent** | Necessary clauses/comments were opened as body text; snippets and indexes served only discovery. Large final-rule and full-part PDFs were read only within reported bounds. | No claim of whole-document review or independent review. |\n\n### Legal-status classification\n\n| Status category | Treatment in this component |\n| --- | --- |\n| **Current retrieved text** | House compilation text, agency operative provisions, and identified annual CFR editions, subject to their exact date and retrieval limits. |\n| **Historical final rules** | Used for adoption, implementation, and model history; former numbering or superseded wording is not applied as current operative text. |\n| **Interim final rule** | S021 is expressly identified as interim final, with its stated effective date; it is not mislabeled a proposal. |\n| **Proposed/future material** | No proposal or unverified future provision supplies an operative result. No comprehensive inventory of pending proposals is claimed. |\n| **Removed/repealed material** | The §31 COVID definition’s regulatory removal is identified. No inference of repeal of §2605 or §1641 follows. |\n| **Withdrawn guidance** | None used; no guidance-withdrawal conclusion needed or made. |\n| **Stayed/vacated/other adverse status** | No provision is labeled stayed or vacated without authority. Conversely, this report does not certify an exhaustive absence of such developments through the check date. |\n| **Unknown** | Exact unresolved retrieval, historical-date, image, currentness, and factual limits are listed above rather than converted into “no rule” findings. |\n\n## 9. Question → claim → source crosswalk\n\n| Assignment question | Principal claims | Principal sources | Supporting deliverable |\n| --- | --- | --- | --- |\n| **1. Necessary coverage, triggers, actors, exclusions, and adjacent definitions** | C001–C020; C038–C044; C058 | S001–S005, S007–S008, S013–S014, S019 | Scope findings; matrix; E01–E02, E07–E08, E12 |\n| **2. Servicing notices, timing, delivery, content, current models** | C018–C031; C062 | S001, S006, S008–S012, S017 | Notice findings; model read bounds; worksheet |\n| **3. Transition payments, receipt, grace period, partial/nonreceived payment** | C032–C037; C066 | S001, S007, S009, S011, S017 | Proof-category table; E04–E06, E13 |\n| **4. Ownership acquisition, timing, content, exceptions, multiple transfers, agents, proof limits** | C038–C061 | S003, S013–S020 | Ownership findings; E02–E03, E09–E12 |\n| **5. Comparison, blank audit, at least eight hypothetical branches, no invented dates** | C001, C021–C023, C032, C045, C061, C066 | Underlying sources above | Matrix; 35 blank audit items; E01–E14 |\n| **Source/version/access standards** | C062–C065 | S001–S024 | Source register; read/failure log; status classification |\n| **Owner limits and parent holds** | C061, C066 | Assignment boundaries | Self-check and holds below |\n\n## 10. Self-check — not independent review\n\nThis was a self-check of the research and synthesis, **not independent legal review, component acceptance, or parent closure**.\n\n| Check | Result |\n| --- | --- |\n| Servicing transfer separated from debt ownership and property succession | Yes—separate definitions, duties, and hypothetical branches |\n| Statutory wording separated from regulations, interpretations, and historical preambles | Yes—including the due-date wording and product-scope differences |\n| Necessary operative exceptions and relevant comments read | Yes within reported text bounds; the complete currentness audit remains limited |\n| Mailing of notice separated from receipt of payment | Yes |\n| No universal 60-day holiday, blanket reporting immunity, or presumed cure | Yes |\n| Model content separated from enumerated mandatory content | Yes |\n| Complete MS-2 parsed text distinguished from image inspection | Yes; pixel verification remains unresolved |\n| Ownership notice separated from assignment/security/standing proof | Yes |\n| Multiple transfers, joint acquisitions, partial interests, agents, and contact-only changes addressed | Yes |\n| At least eight hypothetical branches; no identifying entries | Yes—fourteen qualitative branches |\n| No actual-calendar deadline or amount invented | Yes |\n| No actual records, filings, contacts, publication, or individualized decision | Yes |\n| No unreviewed prior-report foundation or subagent review | Yes |\n| Source failures and textual inconsistencies disclosed | Yes |\n\n### Specific parent holds preserved\n\nThe following remain outside this component:\n\n- **Actual contract, debt ownership, assignment, security, title, perfection, standing, accounting, balances, default, and accrual.**\n- **Full servicing-error and information-request systems, loss mitigation, escrow, foreclosure, credit reporting, limitations periods, remedies, and litigation.** Necessary cross-references were identified only to prevent misclassification.\n- **State, local, tribal, foreign-country, product-specific, and consumer/business-law conclusions**, beyond the necessary federal coverage boundaries stated here.\n- **Original-creditor and debt-collector coverage, debt buyers, settlement, insolvency, tax, eligibility, tools, and all other A006 lifecycle stages.**\n- **Any R002/R004 followup foundation**, which was not supplied, imported, or relied upon.\n- **Actual liability, eligibility, creditworthiness, enforcement, filing, or operational decisions.**\n- **Component, state, parent, operations, or publication acceptance.**\n\nEND R006 PASS-01\n\n","tables":[{"headers":["Dimension","Servicing-transfer regime","Ownership-transfer regime"],"index":0,"links":[],"row_links":[[],[],[],[],[],[],[],[],[],[],[]],"rows":[["Dimension","Servicing-transfer regime","Ownership-transfer regime"],["Principal authorities","12 USC §2605(b)–(d), with definitions in §2605(i); Regulation X §§1024.30–.33 and necessary adjacent provisions.","15 USC §1641(g), with relevant §1641(f); Regulation Z §1026.39 and necessary definitions and interpretations."],["Actor owing the transfer notice","Ordinarily each transferor and transferee servicer; a qualifying combined notice can satisfy both duties. C018–C023.","The acquiring covered person. These provisions do not establish a corresponding general seller-side ownership notice. C038, C042."],["Trigger","Assignment, sale, or transfer of servicing, subject to specified exclusions. C012, C018–C020.","Acquisition of legal title to an existing debt obligation, with the covered-person threshold and exceptions. C042–C049."],["Product boundary","Regulation X Subpart C uses “mortgage loan”: a federally related mortgage loan subject to §1024.5(b), excluding open-end home-equity plans. Section 2605 itself uses “federally related mortgage loan”; its text does not reproduce that express HELOC exclusion. C002–C008.","Section 1641(g) refers to consumer credit secured by the consumer’s principal dwelling. Current §1026.39 separately covers open-end consumer credit secured by a principal dwelling and closed-end consumer credit secured by a dwelling or real property. C038–C041."],["Ordinary clock","Transferor: at least 15 calendar days before the servicing effective date. Transferee: no later than 15 calendar days after. Combined servicing notice: at least 15 calendar days before. C021.","Mail or deliver by the 30th calendar day following the transfer date recognized under §1026.39(b)(2). C045."],["Clock-defining event","Generally, when the borrower’s payment is first due to the transferee servicer; special agreed-date definition for reverse mortgages. C013.","Acquiring party’s recognized acquisition date or transferring party’s recognized transfer date, at the covered person’s option under the rule. C045."],["Core content","Effective date; both servicing contacts; payment acceptance transition dates; optional-insurance effects and actions; statement about unchanged nonservicing terms. C026–C028.","Loan identification; new owner contact; transfer date; authorized contact; recording-location disclosure or permitted alternative; applicable partial-payment policy. C052–C056."],["Conditional exceptions","Specified unchanged-payment affiliate/merger/master-servicer transfers; FHA provision; specified extended timing; settlement timing; applicable successor procedure. C016–C023.","Timely disposition of all interest; qualifying repurchase arrangement; qualifying partial-interest acquisition without the specified contact change; successor provision. C047–C049, C058."],["Payment-transition protection","Conditional §1024.33(c)(1) protection, plus separate prompt-forward-or-return duty under (c)(2). C032–C037.","Section 1026.39 does not itself create the servicing-transfer 60-day protection. Its partial-payment provision is a disclosure requirement. C056, C061."],["What a notice cannot establish by itself","Debt ownership, valid assignment, secured rights, perfection, balance, default, or standing.","Actual valid acquisition, enforceable security rights, recording validity, balance, default, or standing. C061."]]},{"headers":["Source ID","Issuer/title and complete literal HTTPS URL(s)","Exact read bounds / pinpoint","Version and effective predicate; read status and currentness limit"],"index":1,"links":[{"href":"https://uscode.house.gov/us/usc/119-124/t12/s2605/?utm_source=chatgpt.com","text":"https://uscode.house.gov/us/usc/119-124/t12/s2605/"},{"href":"https://www.govinfo.gov/content/pkg/USCODE-2024-title12/html/USCODE-2024-title12-chap27-sec2605.htm?utm_source=chatgpt.com","text":"https://www.govinfo.gov/content/pkg/USCODE-2024-title12/html/USCODE-2024-title12-chap27-sec2605.htm"},{"href":"https://uscode.house.gov/us/usc/119-124/t12/s2605/?utm_source=chatgpt.com","text":"uscode.house.gov\n+2"},{"href":"https://uscode.house.gov/us/usc/119-124/t12/s2602/?utm_source=chatgpt.com","text":"https://uscode.house.gov/us/usc/119-124/t12/s2602/"},{"href":"https://uscode.house.gov/us/usc/119-124/t12/s2606/?utm_source=chatgpt.com","text":"https://uscode.house.gov/us/usc/119-124/t12/s2606/"},{"href":"https://www.govinfo.gov/content/pkg/USCODE-2024-title12/html/USCODE-2024-title12-chap27-sec2602.htm?utm_source=chatgpt.com","text":"https://www.govinfo.gov/content/pkg/USCODE-2024-title12/html/USCODE-2024-title12-chap27-sec2602.htm"},{"href":"https://www.govinfo.gov/link/uscode/12/2606?utm_source=chatgpt.com","text":"https://www.govinfo.gov/link/uscode/12/2606"},{"href":"https://uscode.house.gov/us/usc/119-124/t12/s2602/?utm_source=chatgpt.com","text":"uscode.house.gov\n+2"},{"href":"https://uscode.house.gov/us/usc/119-134/t15/s1641/?utm_source=chatgpt.com","text":"https://uscode.house.gov/us/usc/119-134/t15/s1641/"},{"href":"https://www.govinfo.gov/content/pkg/USCODE-2024-title15/html/USCODE-2024-title15-chap41-subchapI-partB-sec1641.htm?utm_source=chatgpt.com","text":"https://www.govinfo.gov/content/pkg/USCODE-2024-title15/html/USCODE-2024-title15-chap41-subchapI-partB-sec1641.htm"},{"href":"https://uscode.house.gov/us/usc/119-134/t15/s1641/?utm_source=chatgpt.com","text":"uscode.house.gov"},{"href":"https://www.consumerfinance.gov/rules-policy/regulations/1024/2/?utm_source=chatgpt.com","text":"https://www.consumerfinance.gov/rules-policy/regulations/1024/2/"},{"href":"https://www.consumerfinance.gov/rules-policy/regulations/1024/2/?utm_source=chatgpt.com","text":"Consumer 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Bureau"},{"href":"https://www.govinfo.gov/content/pkg/CFR-2025-title12-vol9/pdf/CFR-2025-title12-vol9-sec1026-39.pdf?utm_source=chatgpt.com","text":"https://www.govinfo.gov/content/pkg/CFR-2025-title12-vol9/pdf/CFR-2025-title12-vol9-sec1026-39.pdf"},{"href":"https://www.govinfo.gov/link/cfr/12/1026?link-type=pdf&sectionnum=39&year=mostrecent&utm_source=chatgpt.com","text":"https://www.govinfo.gov/link/cfr/12/1026?link-type=pdf&sectionnum=39&year=mostrecent"},{"href":"https://www.govinfo.gov/content/pkg/CFR-2025-title12-vol9/pdf/CFR-2025-title12-vol9-sec1026-39.pdf?utm_source=chatgpt.com","text":"govinfo.gov\n+1"}],"row_links":[[],[{"href":"https://uscode.house.gov/us/usc/119-124/t12/s2605/?utm_source=chatgpt.com","text":"https://uscode.house.gov/us/usc/119-124/t12/s2605/"},{"href":"https://www.govinfo.gov/content/pkg/USCODE-2024-title12/html/USCODE-2024-title12-chap27-sec2605.htm?utm_source=chatgpt.com","text":"https://www.govinfo.gov/content/pkg/USCODE-2024-title12/html/USCODE-2024-title12-chap27-sec2605.htm"},{"href":"https://uscode.house.gov/us/usc/119-124/t12/s2605/?utm_source=chatgpt.com","text":"uscode.house.gov\n+2"}],[{"href":"https://uscode.house.gov/us/usc/119-124/t12/s2602/?utm_source=chatgpt.com","text":"https://uscode.house.gov/us/usc/119-124/t12/s2602/"},{"href":"https://uscode.house.gov/us/usc/119-124/t12/s2606/?utm_source=chatgpt.com","text":"https://uscode.house.gov/us/usc/119-124/t12/s2606/"},{"href":"https://www.govinfo.gov/content/pkg/USCODE-2024-title12/html/USCODE-2024-title12-chap27-sec2602.htm?utm_source=chatgpt.com","text":"https://www.govinfo.gov/content/pkg/USCODE-2024-title12/html/USCODE-2024-title12-chap27-sec2602.htm"},{"href":"https://www.govinfo.gov/link/uscode/12/2606?utm_source=chatgpt.com","text":"https://www.govinfo.gov/link/uscode/12/2606"},{"href":"https://uscode.house.gov/us/usc/119-124/t12/s2602/?utm_source=chatgpt.com","text":"uscode.house.gov\n+2"}],[{"href":"https://uscode.house.gov/us/usc/119-134/t15/s1641/?utm_source=chatgpt.com","text":"https://uscode.house.gov/us/usc/119-134/t15/s1641/"},{"href":"https://www.govinfo.gov/content/pkg/USCODE-2024-title15/html/USCODE-2024-title15-chap41-subchapI-partB-sec1641.htm?utm_source=chatgpt.com","text":"https://www.govinfo.gov/content/pkg/USCODE-2024-title15/html/USCODE-2024-title15-chap41-subchapI-partB-sec1641.htm"},{"href":"https://uscode.house.gov/us/usc/119-134/t15/s1641/?utm_source=chatgpt.com","text":"uscode.house.gov"}],[{"href":"https://www.consumerfinance.gov/rules-policy/regulations/1024/2/?utm_source=chatgpt.com","text":"https://www.consumerfinance.gov/rules-policy/regulations/1024/2/"},{"href":"https://www.consumerfinance.gov/rules-policy/regulations/1024/2/?utm_source=chatgpt.com","text":"Consumer Financial Protection Bureau\n+1"}],[{"href":"https://www.consumerfinance.gov/rules-policy/regulations/1024/5/?utm_source=chatgpt.com","text":"https://www.consumerfinance.gov/rules-policy/regulations/1024/5/"},{"href":"https://www.consumerfinance.gov/rules-policy/regulations/1024/5/?utm_source=chatgpt.com","text":"Consumer Financial Protection Bureau"}],[{"href":"https://www.consumerfinance.gov/rules-policy/regulations/1024/11/?utm_source=chatgpt.com","text":"https://www.consumerfinance.gov/rules-policy/regulations/1024/11/"},{"href":"https://www.consumerfinance.gov/rules-policy/regulations/1024/11/?utm_source=chatgpt.com","text":"Consumer Financial Protection Bureau"}],[{"href":"https://www.consumerfinance.gov/rules-policy/regulations/1024/30/?utm_source=chatgpt.com","text":"https://www.consumerfinance.gov/rules-policy/regulations/1024/30/"},{"href":"https://www.consumerfinance.gov/rules-policy/regulations/1024/31/?utm_source=chatgpt.com","text":"https://www.consumerfinance.gov/rules-policy/regulations/1024/31/"},{"href":"https://www.consumerfinance.gov/rules-policy/regulations/1024/interp-31/?utm_source=chatgpt.com","text":"https://www.consumerfinance.gov/rules-policy/regulations/1024/interp-31/"},{"href":"https://www.consumerfinance.gov/rules-policy/regulations/1024/30/?utm_source=chatgpt.com","text":"Consumer Financial Protection Bureau\n+3"}],[{"href":"https://www.consumerfinance.gov/rules-policy/regulations/1024/32/?utm_source=chatgpt.com","text":"https://www.consumerfinance.gov/rules-policy/regulations/1024/32/"},{"href":"https://www.consumerfinance.gov/rules-policy/regulations/1024/32/?utm_source=chatgpt.com","text":"Consumer Financial Protection Bureau\n+2"}],[{"href":"https://www.consumerfinance.gov/rules-policy/regulations/1024/33/?utm_source=chatgpt.com","text":"https://www.consumerfinance.gov/rules-policy/regulations/1024/33/"},{"href":"https://www.consumerfinance.gov/rules-policy/regulations/1024/interp-33/?utm_source=chatgpt.com","text":"https://www.consumerfinance.gov/rules-policy/regulations/1024/interp-33/"},{"href":"https://www.consumerfinance.gov/rules-policy/regulations/1024/33/?utm_source=chatgpt.com","text":"Consumer Financial Protection Bureau\n+2"}],[{"href":"https://www.consumerfinance.gov/rules-policy/regulations/1024/ms/?utm_source=chatgpt.com","text":"https://www.consumerfinance.gov/rules-policy/regulations/1024/ms/"},{"href":"https://www.consumerfinance.gov/rules-policy/regulations/1024/ms2/?utm_source=chatgpt.com","text":"https://www.consumerfinance.gov/rules-policy/regulations/1024/ms2/"},{"href":"https://www.consumerfinance.gov/rules-policy/regulations/1024/interp-ms/?utm_source=chatgpt.com","text":"https://www.consumerfinance.gov/rules-policy/regulations/1024/interp-ms/"},{"href":"https://www.consumerfinance.gov/rules-policy/regulations/1024/ms2/?utm_source=chatgpt.com","text":"Consumer Financial Protection Bureau\n+2"}],[{"href":"https://www.govinfo.gov/content/pkg/CFR-2026-title12-vol8/pdf/CFR-2026-title12-vol8-sec1024-33.pdf?utm_source=chatgpt.com","text":"https://www.govinfo.gov/content/pkg/CFR-2026-title12-vol8/pdf/CFR-2026-title12-vol8-sec1024-33.pdf"},{"href":"https://www.govinfo.gov/content/pkg/CFR-2026-title12-vol8/pdf/CFR-2026-title12-vol8-part1024.pdf?utm_source=chatgpt.com","text":"https://www.govinfo.gov/content/pkg/CFR-2026-title12-vol8/pdf/CFR-2026-title12-vol8-part1024.pdf"},{"href":"https://www.govinfo.gov/content/pkg/CFR-2026-title12-vol8/pdf/CFR-2026-title12-vol8-sec1024-33.pdf?utm_source=chatgpt.com","text":"govinfo.gov\n+3"}],[{"href":"https://www.govinfo.gov/content/pkg/CFR-2025-title12-vol8/pdf/CFR-2025-title12-vol8-sec1024-33.pdf?utm_source=chatgpt.com","text":"https://www.govinfo.gov/content/pkg/CFR-2025-title12-vol8/pdf/CFR-2025-title12-vol8-sec1024-33.pdf"},{"href":"https://www.govinfo.gov/content/pkg/CFR-2025-title12-vol8/pdf/CFR-2025-title12-vol8-part1024.pdf?utm_source=chatgpt.com","text":"https://www.govinfo.gov/content/pkg/CFR-2025-title12-vol8/pdf/CFR-2025-title12-vol8-part1024.pdf"},{"href":"https://www.govinfo.gov/content/pkg/CFR-2025-title12-vol8/pdf/CFR-2025-title12-vol8-part1024-appMS.pdf?utm_source=chatgpt.com","text":"https://www.govinfo.gov/content/pkg/CFR-2025-title12-vol8/pdf/CFR-2025-title12-vol8-part1024-appMS.pdf"},{"href":"https://www.govinfo.gov/content/pkg/CFR-2025-title12-vol8/pdf/CFR-2025-title12-vol8-part1024.pdf?utm_source=chatgpt.com","text":"govinfo.gov\n+2"}],[{"href":"https://www.consumerfinance.gov/rules-policy/regulations/1026/2/?utm_source=chatgpt.com","text":"https://www.consumerfinance.gov/rules-policy/regulations/1026/2/"},{"href":"https://www.consumerfinance.gov/rules-policy/regulations/1026/3/?utm_source=chatgpt.com","text":"https://www.consumerfinance.gov/rules-policy/regulations/1026/3/"},{"href":"https://www.consumerfinance.gov/rules-policy/regulations/1026/2/?utm_source=chatgpt.com","text":"Consumer Financial Protection Bureau\n+3"}],[{"href":"https://www.consumerfinance.gov/rules-policy/regulations/1026/39/?utm_source=chatgpt.com","text":"https://www.consumerfinance.gov/rules-policy/regulations/1026/39/"},{"href":"https://www.consumerfinance.gov/rules-policy/regulations/1026/interp-39/?utm_source=chatgpt.com","text":"https://www.consumerfinance.gov/rules-policy/regulations/1026/interp-39/"},{"href":"https://www.consumerfinance.gov/rules-policy/regulations/1026/39/?utm_source=chatgpt.com","text":"Consumer Financial Protection Bureau\n+3"}],[{"href":"https://www.consumerfinance.gov/rules-policy/regulations/1026/1/?utm_source=chatgpt.com","text":"https://www.consumerfinance.gov/rules-policy/regulations/1026/1/"},{"href":"https://www.consumerfinance.gov/rules-policy/regulations/1026/1/?utm_source=chatgpt.com","text":"Consumer Financial Protection Bureau"}],[{"href":"https://www.govinfo.gov/content/pkg/CFR-2025-title12-vol9/pdf/CFR-2025-title12-vol9-sec1026-39.pdf?utm_source=chatgpt.com","text":"https://www.govinfo.gov/content/pkg/CFR-2025-title12-vol9/pdf/CFR-2025-title12-vol9-sec1026-39.pdf"},{"href":"https://www.govinfo.gov/link/cfr/12/1026?link-type=pdf&sectionnum=39&year=mostrecent&utm_source=chatgpt.com","text":"https://www.govinfo.gov/link/cfr/12/1026?link-type=pdf&sectionnum=39&year=mostrecent"},{"href":"https://www.govinfo.gov/content/pkg/CFR-2025-title12-vol9/pdf/CFR-2025-title12-vol9-sec1026-39.pdf?utm_source=chatgpt.com","text":"govinfo.gov\n+1"}]],"rows":[["Source ID","Issuer/title and complete literal HTTPS URL(s)","Exact read bounds / pinpoint","Version and effective predicate; read status and currentness limit"],["R006-P1-S001","House Office of Law Revision Counsel, 12 USC §2605, Servicing of mortgage loans and administration of escrow accounts.\nhttps://uscode.house.gov/us/usc/119-124/t12/s2605/\nEarlier GPO compilation:\nhttps://www.govinfo.gov/content/pkg/USCODE-2024-title12/html/USCODE-2024-title12-chap27-sec2605.htm","Complete necessary (b), (c), (d), (h), (i), (j); (a) for the application/transfer distinction. Adjacent (e)(3) read only to distinguish its separate credit-reporting clock. Other displayed provisions were not analyzed as assigned subjects.","House: laws in effect through PL119-124, October 15, 2026. GPO: 2024 edition, initially read, then superseded for current statutory wording by the House read. Fresh; reused. Statutory notice and payment triggers are in the cited subsections. No full post-compilation session-law audit. \nuscode.house.gov\n+2"],["R006-P1-S002","House OLRC, 12 USC §§2602 and 2606, definitions and exempted transactions.\nhttps://uscode.house.gov/us/usc/119-124/t12/s2602/\nhttps://uscode.house.gov/us/usc/119-124/t12/s2606/\nEarlier reads:\nhttps://www.govinfo.gov/content/pkg/USCODE-2024-title12/html/USCODE-2024-title12-chap27-sec2602.htm\nhttps://www.govinfo.gov/link/uscode/12/2606","§2602 (1), (5) and relevant editorial notes; complete §2606 (a)–(b). The §2606 GovInfo PDF was printed p.1452, index 0, parsed text only.","House: through PL119-124, October 15, 2026. Earlier §2602 HTML: 2024. Edition of the isolated §2606 link PDF was not independently established; the later House read supplies the reported compilation version. Fresh; reused. \nuscode.house.gov\n+2"],["R006-P1-S003","House OLRC, 15 USC §1641, Liability of assignees.\nhttps://uscode.house.gov/us/usc/119-134/t15/s1641/\nEarlier GPO compilation:\nhttps://www.govinfo.gov/content/pkg/USCODE-2024-title15/html/USCODE-2024-title15-chap41-subchapI-partB-sec1641.htm","Complete necessary (f) and (g); source credit and amendment notes. Other liability provisions displayed on the page are outside this component.","House: through PL119-134, October 20, 2026. Subsection (g) added by PL111-22, May 20, 2009. Earlier GPO 2024 text freshly read, then checked against House. No remedies analysis or full later-law audit. \nuscode.house.gov"],["R006-P1-S004","CFPB, Regulation X §1024.2, Definitions.\nhttps://www.consumerfinance.gov/rules-policy/regulations/1024/2/","Complete necessary definitions of business day; effective date of transfer; federally related mortgage loan; servicer; servicing; State; table funding, and relevant lender/dealer/broker definitions.","Agency page labeled current; part-version limitation in S022. Fresh selected-body read. Necessary federal nexus, property, actor, and reverse-mortgage conditions read in full; no general underwriting analysis. \nConsumer Financial Protection Bureau\n+1"],["R006-P1-S005","CFPB, §1024.5, Coverage of RESPA.\nhttps://www.consumerfinance.gov/rules-policy/regulations/1024/5/","Complete (a)–(d) and relevant embedded official interpretations, particularly (b)(2)–(7), (c)(1), (c)(4), (d).","Agency-current label, subject to S022. Fresh full operative section read. Exceptions are section-specific; secondary-market and partial exemptions cannot be generalized. \nConsumer Financial Protection Bureau"],["R006-P1-S006","CFPB, §1024.11, Mailing.\nhttps://www.consumerfinance.gov/rules-policy/regulations/1024/11/","Entire operative mailing paragraph.","Agency-current label. Fresh full-body read. Applies by its terms to mailing provisions of “this part”; used together with transfer-specific address interpretation, not as a payment-receipt rule. \nConsumer Financial Protection Bureau"],["R006-P1-S007","CFPB, §§1024.30–.31, scope, definitions, and official interpretations.\nhttps://www.consumerfinance.gov/rules-policy/regulations/1024/30/\nhttps://www.consumerfinance.gov/rules-policy/regulations/1024/31/\nhttps://www.consumerfinance.gov/rules-policy/regulations/1024/interp-31/","§30 (a)–(d) and comments; §31 necessary definitions, including day, mortgage loan, master/subservicer, transferor/transferee, successor and confirmed successor; official Delinquency comments 1–4 and Successor comments 1–2.","Fresh; reused. The agency §31 page still displays the later-removed COVID definition. That stale item is not used; S011 and S021 address the discrepancy. Successor amendments relevant here took effect April 19, 2018. \nConsumer Financial Protection Bureau\n+3"],["R006-P1-S008","CFPB, §1024.32, General disclosure requirements.\nhttps://www.consumerfinance.gov/rules-policy/regulations/1024/32/","Complete (a)–(c) and embedded interpretations, including 32(c)(1)-1; 32(c)(2)-1 and -2.","Fresh full necessary body/comments. Successor procedure effective April 19, 2018, S019. No inference that a generic acknowledgment establishes actual personal liability or valid security rights. \nConsumer Financial Protection Bureau\n+2"],["R006-P1-S009","CFPB, §1024.33, Mortgage servicing transfers, and Supplement I.\nhttps://www.consumerfinance.gov/rules-policy/regulations/1024/33/\nhttps://www.consumerfinance.gov/rules-policy/regulations/1024/interp-33/","Complete (a)–(d); comments 33(a)-1 through -3; 33(b)(3)-1; 33(c)(1)-1 and -2.","Fresh complete operative section and necessary comments. Current posting checked against 2026 annual CFR §33. Core 2013 servicing rule effective January 10, 2014; later amendment/history separately identified below. \nConsumer Financial Protection Bureau\n+2"],["R006-P1-S010","CFPB, Appendix MS, MS-2, and official model instructions.\nhttps://www.consumerfinance.gov/rules-policy/regulations/1024/ms/\nhttps://www.consumerfinance.gov/rules-policy/regulations/1024/ms2/\nhttps://www.consumerfinance.gov/rules-policy/regulations/1024/interp-ms/","Entire posted MS-2 notice text. Appendix MS general instructions 1–2, with complete continuation/examples verified in annual CFR rather than assuming the website excerpt was complete.","Fresh. Current generic model, not an actual notice. Model use is optional and conditional. No H-25 form was used or claimed to have been inspected. \nConsumer Financial Protection Bureau\n+2"],["R006-P1-S011","OFR/GPO, 2026 annual CFR, Regulation X.\nhttps://www.govinfo.gov/content/pkg/CFR-2026-title12-vol8/pdf/CFR-2026-title12-vol8-sec1024-33.pdf\nhttps://www.govinfo.gov/content/pkg/CFR-2026-title12-vol8/pdf/CFR-2026-title12-vol8-part1024.pdf","§33 granule: printed pp.704–706, indexes 0–2, complete §33. Full-part PDF: selected §§30–32 text pp.702–704, indexes 28–30; relevant comments pp.756–758, indexes 82–84; complete MS-2 pp.752–753, indexes 78–79; complete general MS instructions p.782, index 108.","January 1, 2026 edition; 110-page full-part file not read in full. Parsed-text read. Screenshot requests for indexes 78–79 returned display markers without inspectable image blocks through this tool: no pixel-level verification claimed. Fresh; same-edition reproductions, not independent corroboration. \ngovinfo.gov\n+3"],["R006-P1-S012","OFR/GPO, 2025 annual CFR, Regulation X, earlier verification copies.\nhttps://www.govinfo.gov/content/pkg/CFR-2025-title12-vol8/pdf/CFR-2025-title12-vol8-sec1024-33.pdf\nhttps://www.govinfo.gov/content/pkg/CFR-2025-title12-vol8/pdf/CFR-2025-title12-vol8-part1024.pdf\nhttps://www.govinfo.gov/content/pkg/CFR-2025-title12-vol8/pdf/CFR-2025-title12-vol8-part1024-appMS.pdf","Selected §33; complete MS-2 parsed across pp.754–755, full-part indexes 80–81; general MS instructions p.785, index 111. Isolated appendix granule contains p.754 only, index 0—it is not the complete MS-2.","January 1, 2025 edition, supplanted for annual-edition verification by S011. Screenshot retrieval included a timeout/recovery; no additional pixel-read claim is necessary or made. The 113-page full part was not fully read. \ngovinfo.gov\n+2"],["R006-P1-S013","CFPB, Regulation Z §§1026.2–.3, necessary definitions and exemptions.\nhttps://www.consumerfinance.gov/rules-policy/regulations/1026/2/\nhttps://www.consumerfinance.gov/rules-policy/regulations/1026/3/","§2 (a)(6), (10)–(12), (19), (22), (27) and relevant consumer, dwelling, person, trust, and successor comments; §3 (a)(1)–(2) and corresponding interpretations.","Fresh selected-body read. Consumer-purpose and organizational-credit boundaries examined only as necessary for §39; no comprehensive origination, underwriting, or general Regulation Z gateway rerun. \nConsumer Financial Protection Bureau\n+3"],["R006-P1-S014","CFPB, §1026.39, Mortgage transfer disclosures, and Supplement I.\nhttps://www.consumerfinance.gov/rules-policy/regulations/1026/39/\nhttps://www.consumerfinance.gov/rules-policy/regulations/1026/interp-39/","Complete (a)–(f) and relevant embedded official comments: 39(a)(1)-1–4; (a)(2)-1; (b)(1)-1; (b)(4)-1–3; (b)(5)-1–4; (c)(1)-1–2; (c)(2)-1; (c)(3)-1–2; (d)-1–2; (d)(1)-1; (d)(1)(i)-1; (d)(1)(ii)-1; (d)(3)-1–2; (d)(4)-1; (d)(5)-1; (e)-1.","Fresh complete operative body/comments through the integrated page; standalone interpretation page used as associated source, not separate corroboration. Agency-current label subject to S022. Two textual inconsistencies are expressly recorded below. \nConsumer Financial Protection Bureau\n+3"],["R006-P1-S015","CFPB, §1026.1, necessary implementation provisions and comments.\nhttps://www.consumerfinance.gov/rules-policy/regulations/1026/1/","(c)(5); necessary (d)(5) material and comment 1(d)(5)-1, particularly the post-consummation treatment of §39(d)(5).","Fresh selected read. Partial-payment disclosure implementation: October 3, 2015 transition; triggering conditions on or after October 1, 2018 apply regardless of application date. No general TRID analysis. \nConsumer Financial Protection Bureau"],["R006-P1-S016","OFR/GPO, 2025 annual CFR §1026.39.\nhttps://www.govinfo.gov/content/pkg/CFR-2025-title12-vol9/pdf/CFR-2025-title12-vol9-sec1026-39.pdf\nhttps://www.govinfo.gov/link/cfr/12/1026?link-type=pdf&sectionnum=39&year=mostrecent","Complete §39, printed pp.139–141, indexes 0–2; neighboring §38/§40 fragments not treated as complete reads.","Both routes returned the January 1, 2025 edition. Fresh parsed-text read; no image inspection. “Most recent” routing is not proof that a 2026 edition does not exist. \ngovinfo.gov\n+1"]]},{"headers":["Source ID","Issuer/title and complete literal HTTPS URL(s)","Exact read bounds / pinpoint","Version/effective predicate; status and limits"],"index":2,"links":[{"href":"https://www.govinfo.gov/content/pkg/FR-2013-02-14/pdf/2013-01248.pdf?utm_source=chatgpt.com","text":"https://www.govinfo.gov/content/pkg/FR-2013-02-14/pdf/2013-01248.pdf"},{"href":"https://www.govinfo.gov/content/pkg/FR-2013-02-14/pdf/2013-01248.pdf?utm_source=chatgpt.com","text":"govinfo.gov\n+2"},{"href":"https://www.govinfo.gov/content/pkg/FR-2013-12-31/html/2013-28210.htm?utm_source=chatgpt.com","text":"https://www.govinfo.gov/content/pkg/FR-2013-12-31/html/2013-28210.htm"},{"href":"https://www.govinfo.gov/content/pkg/FR-2013-12-31/html/2013-28210.htm?utm_source=chatgpt.com","text":"govinfo.gov\n+2"},{"href":"https://www.govinfo.gov/content/pkg/FR-2016-10-19/pdf/2016-18901.pdf?utm_source=chatgpt.com","text":"https://www.govinfo.gov/content/pkg/FR-2016-10-19/pdf/2016-18901.pdf"},{"href":"https://www.govinfo.gov/content/pkg/FR-2016-10-19/pdf/2016-18901.pdf?utm_source=chatgpt.com","text":"govinfo.gov\n+1"},{"href":"https://www.govinfo.gov/content/pkg/FR-2010-09-24/pdf/2010-20664.pdf?utm_source=chatgpt.com","text":"https://www.govinfo.gov/content/pkg/FR-2010-09-24/pdf/2010-20664.pdf"},{"href":"https://www.govinfo.gov/content/pkg/FR-2010-09-24/pdf/2010-20664.pdf?utm_source=chatgpt.com","text":"govinfo.gov\n+2"},{"href":"https://www.govinfo.gov/content/pkg/FR-2025-05-16/pdf/2025-08643.pdf?utm_source=chatgpt.com","text":"https://www.govinfo.gov/content/pkg/FR-2025-05-16/pdf/2025-08643.pdf"},{"href":"https://www.federalregister.gov/documents/2025/05/16/2025-08643/protections-for-borrowers-affected-by-the-covid-19-emergency-under-the-real-estate-settlement?utm_source=chatgpt.com","text":"https://www.federalregister.gov/documents/2025/05/16/2025-08643/protections-for-borrowers-affected-by-the-covid-19-emergency-under-the-real-estate-settlement"},{"href":"https://www.govinfo.gov/content/pkg/FR-2025-05-16/pdf/2025-08643.pdf?utm_source=chatgpt.com","text":"govinfo.gov\n+1"},{"href":"https://www.consumerfinance.gov/rules-policy/regulations/1024/versions/33/?utm_source=chatgpt.com","text":"https://www.consumerfinance.gov/rules-policy/regulations/1024/versions/33/"},{"href":"https://www.consumerfinance.gov/rules-policy/regulations/1026/versions/39/?utm_source=chatgpt.com","text":"https://www.consumerfinance.gov/rules-policy/regulations/1026/versions/39/"},{"href":"https://www.consumerfinance.gov/rules-policy/regulations/1024/versions/33/?utm_source=chatgpt.com","text":"Consumer Financial Protection Bureau\n+1"},{"href":"https://www.ecfr.gov/current/title-12/chapter-X/part-1024/section-1024.33","text":"https://www.ecfr.gov/current/title-12/chapter-X/part-1024/section-1024.33"},{"href":"https://www.ecfr.gov/current/title-12/chapter-X/part-1026/section-1026.39","text":"https://www.ecfr.gov/current/title-12/chapter-X/part-1026/section-1026.39"},{"href":"https://ecfr.federalregister.gov/current/title-12/chapter-X/part-1024/section-1024.33","text":"https://ecfr.federalregister.gov/current/title-12/chapter-X/part-1024/section-1024.33"},{"href":"https://ecfr.federalregister.gov/current/title-12/chapter-X/part-1026/section-1026.39","text":"https://ecfr.federalregister.gov/current/title-12/chapter-X/part-1026/section-1026.39"},{"href":"https://www.govinfo.gov/content/pkg/CFR-2026-title12-vol9/pdf/CFR-2026-title12-vol9-sec1026-39.pdf","text":"https://www.govinfo.gov/content/pkg/CFR-2026-title12-vol9/pdf/CFR-2026-title12-vol9-sec1026-39.pdf"}],"row_links":[[],[{"href":"https://www.govinfo.gov/content/pkg/FR-2013-02-14/pdf/2013-01248.pdf?utm_source=chatgpt.com","text":"https://www.govinfo.gov/content/pkg/FR-2013-02-14/pdf/2013-01248.pdf"},{"href":"https://www.govinfo.gov/content/pkg/FR-2013-02-14/pdf/2013-01248.pdf?utm_source=chatgpt.com","text":"govinfo.gov\n+2"}],[{"href":"https://www.govinfo.gov/content/pkg/FR-2013-12-31/html/2013-28210.htm?utm_source=chatgpt.com","text":"https://www.govinfo.gov/content/pkg/FR-2013-12-31/html/2013-28210.htm"},{"href":"https://www.govinfo.gov/content/pkg/FR-2013-12-31/html/2013-28210.htm?utm_source=chatgpt.com","text":"govinfo.gov\n+2"}],[{"href":"https://www.govinfo.gov/content/pkg/FR-2016-10-19/pdf/2016-18901.pdf?utm_source=chatgpt.com","text":"https://www.govinfo.gov/content/pkg/FR-2016-10-19/pdf/2016-18901.pdf"},{"href":"https://www.govinfo.gov/content/pkg/FR-2016-10-19/pdf/2016-18901.pdf?utm_source=chatgpt.com","text":"govinfo.gov\n+1"}],[{"href":"https://www.govinfo.gov/content/pkg/FR-2010-09-24/pdf/2010-20664.pdf?utm_source=chatgpt.com","text":"https://www.govinfo.gov/content/pkg/FR-2010-09-24/pdf/2010-20664.pdf"},{"href":"https://www.govinfo.gov/content/pkg/FR-2010-09-24/pdf/2010-20664.pdf?utm_source=chatgpt.com","text":"govinfo.gov\n+2"}],[{"href":"https://www.govinfo.gov/content/pkg/FR-2025-05-16/pdf/2025-08643.pdf?utm_source=chatgpt.com","text":"https://www.govinfo.gov/content/pkg/FR-2025-05-16/pdf/2025-08643.pdf"},{"href":"https://www.federalregister.gov/documents/2025/05/16/2025-08643/protections-for-borrowers-affected-by-the-covid-19-emergency-under-the-real-estate-settlement?utm_source=chatgpt.com","text":"https://www.federalregister.gov/documents/2025/05/16/2025-08643/protections-for-borrowers-affected-by-the-covid-19-emergency-under-the-real-estate-settlement"},{"href":"https://www.govinfo.gov/content/pkg/FR-2025-05-16/pdf/2025-08643.pdf?utm_source=chatgpt.com","text":"govinfo.gov\n+1"}],[{"href":"https://www.consumerfinance.gov/rules-policy/regulations/1024/versions/33/?utm_source=chatgpt.com","text":"https://www.consumerfinance.gov/rules-policy/regulations/1024/versions/33/"},{"href":"https://www.consumerfinance.gov/rules-policy/regulations/1026/versions/39/?utm_source=chatgpt.com","text":"https://www.consumerfinance.gov/rules-policy/regulations/1026/versions/39/"},{"href":"https://www.consumerfinance.gov/rules-policy/regulations/1024/versions/33/?utm_source=chatgpt.com","text":"Consumer Financial Protection Bureau\n+1"}],[{"href":"https://www.ecfr.gov/current/title-12/chapter-X/part-1024/section-1024.33","text":"https://www.ecfr.gov/current/title-12/chapter-X/part-1024/section-1024.33"},{"href":"https://www.ecfr.gov/current/title-12/chapter-X/part-1026/section-1026.39","text":"https://www.ecfr.gov/current/title-12/chapter-X/part-1026/section-1026.39"},{"href":"https://ecfr.federalregister.gov/current/title-12/chapter-X/part-1024/section-1024.33","text":"https://ecfr.federalregister.gov/current/title-12/chapter-X/part-1024/section-1024.33"},{"href":"https://ecfr.federalregister.gov/current/title-12/chapter-X/part-1026/section-1026.39","text":"https://ecfr.federalregister.gov/current/title-12/chapter-X/part-1026/section-1026.39"}],[{"href":"https://www.govinfo.gov/content/pkg/CFR-2026-title12-vol9/pdf/CFR-2026-title12-vol9-sec1026-39.pdf","text":"https://www.govinfo.gov/content/pkg/CFR-2026-title12-vol9/pdf/CFR-2026-title12-vol9-sec1026-39.pdf"}]],"rows":[["Source ID","Issuer/title and complete literal HTTPS URL(s)","Exact read bounds / pinpoint","Version/effective predicate; status and limits"],["R006-P1-S017","CFPB/OFR/GPO, Mortgage Servicing Rules Under RESPA (Regulation X), 2013 final rule.\nhttps://www.govinfo.gov/content/pkg/FR-2013-02-14/pdf/2013-01248.pdf","Front effective-date text; selected §33 discussion printed pp.10727–10734, indexes 31–38; MS model discussion p.10839, index 143. Particularly payment-address treatment, complaint-resolution language, retained 60-day paragraph, and forwarding/return.","Published February 14, 2013; relevant servicing rule effective January 10, 2014. Historical final-rule explanation, not a substitute for current codified text. The 204-page PDF was not fully read. No case cited inside its preamble was treated as a read opinion. \ngovinfo.gov\n+2"],["R006-P1-S018","CFPB/OFR/GPO, Integrated Mortgage Disclosures, 2013 final rule.\nhttps://www.govinfo.gov/content/pkg/FR-2013-12-31/html/2013-28210.htm","Selected §39 discussion printed pp.80058–80060; amendment p.80130; comments p.80363. HTML printed-page markers, no PDF index.","Final amendment expanded closed-end scope and added partial-payment disclosure. Original implementation dates were later modified; S015 supplies the relevant operative transition explanation. Selected body read, not the entire large rule. \ngovinfo.gov\n+2"],["R006-P1-S019","CFPB/OFR/GPO, 2016 Mortgage Servicing Amendments.\nhttps://www.govinfo.gov/content/pkg/FR-2016-10-19/pdf/2016-18901.pdf","Front dates; selected successor amendments/discussion; §39(f) discussion p.72299, index 139; instruction 22 and §39(f) p.72388, index 228.","Published October 19, 2016. Relevant successor provisions effective April 19, 2018, distinct from the rule’s general October 19, 2017 date. Selected read of a 242-page PDF. \ngovinfo.gov\n+1"],["R006-P1-S020","Federal Reserve/OFR/GPO, 2010 Regulation Z final rule and official staff commentary, former §226.39.\nhttps://www.govinfo.gov/content/pkg/FR-2010-09-24/pdf/2010-20664.pdf","Front matter p.58489/index 0; selected ownership, multiple-transfer, exception and agent discussions pp.58491–58498/indexes 2–9; effective-date discussion p.58500/index 11; relevant former-rule/comment excerpts pp.58501–58504/indexes 12–15.","Historical authority only. Front dates say January 1, 2011; §VI says effective October 25, 2010 with January 1, 2011 mandatory compliance. That internal historical-date discrepancy is preserved, not resolved. Both passages distinguish the statute’s May 20, 2009 enactment/effect. Current §1026.39 controls this report. \ngovinfo.gov\n+2"],["R006-P1-S021","CFPB/OFR/GPO, 2025 COVID-era Regulation X rescission, interim final rule.\nhttps://www.govinfo.gov/content/pkg/FR-2025-05-16/pdf/2025-08643.pdf\nhttps://www.federalregister.gov/documents/2025/05/16/2025-08643/protections-for-borrowers-affected-by-the-covid-19-emergency-under-the-real-estate-settlement","Effective-date text p.20791/index 0; instruction 2 removing the §31 COVID definition p.20792/index 1; amendment list and necessary cross-reference context.","Interim final, effective July 15, 2025; not merely a proposal. Used to identify the agency-page currency discrepancy, not to reopen loss mitigation or foreclosure subjects. Official PDF checked; no claim to have read the complete five-page PDF. \ngovinfo.gov\n+1"],["R006-P1-S022","CFPB, regulation version lists.\nhttps://www.consumerfinance.gov/rules-policy/regulations/1024/versions/33/\nhttps://www.consumerfinance.gov/rules-policy/regulations/1026/versions/39/","Version-list labels only.","Retrieved lists identify April 19, 2023 for Regulation X and April 8, 2026 for Regulation Z as current versions. These are part-level website labels, not proof of each section’s amendment date or complete legal currency. Fresh metadata read. \nConsumer Financial Protection Bureau\n+1"],["R006-P1-S023","OFR eCFR section retrieval attempts.\nhttps://www.ecfr.gov/current/title-12/chapter-X/part-1024/section-1024.33\nhttps://www.ecfr.gov/current/title-12/chapter-X/part-1026/section-1026.39\nhttps://ecfr.federalregister.gov/current/title-12/chapter-X/part-1024/section-1024.33\nhttps://ecfr.federalregister.gov/current/title-12/chapter-X/part-1026/section-1026.39","No operative body retrieved through these routes.","Failure, not evidence of no rule. Annual CFR, agency text, and final rules supplied the substantive reads. No CAPTCHA or security workaround attempted."],["R006-P1-S024","GovInfo attempted 2026 §1026.39 granule.\nhttps://www.govinfo.gov/content/pkg/CFR-2026-title12-vol9/pdf/CFR-2026-title12-vol9-sec1026-39.pdf","No body retrieved.","Failure. The alternative most-recent route returned S016’s 2025 edition. A fully verified 2026 annual §39 granule remains a precise source gap."]]},{"headers":["Claim ID","Area and precise claim","Trigger, conditions, and exceptions","Source pinpoint","Status / limit"],"index":3,"links":[],"row_links":[[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[]],"rows":[["Claim ID","Area and precise claim","Trigger, conditions, and exceptions","Source pinpoint","Status / limit"],["R006-P1-C001","Servicing rights, ownership of the debt, and ownership of property securing the debt are separate subjects in these provisions.","A single transaction may affect more than one, but one label does not establish the others.","S001 §2605(i); S007 §31; S014 §39(a)(1).","R/S; separation and proof limitation are I."],["R006-P1-C002","RESPA’s statutory federally related mortgage-loan definition requires qualifying residential collateral and a specified federal/lender nexus.","First or subordinate lien on principally one-to-four-family residential real property; non-temporary financing; federally insured/regulated lender, federal assistance, intended specified secondary-market sale, or qualifying creditor making/investing more than $1 million per year in residential real-estate loans. State agencies are excluded from that last creditor branch.","S002 §2602(1)(A)–(B).","S; collateral alone is insufficient."],["R006-P1-C003","Regulation X adds necessary detail concerning residential structures, manufactured homes, dealer/broker originations, reverse mortgages, and financed land/installment contracts.","Apply each §2 definition branch. The security must be in a defined “State,” including DC, Puerto Rico, and US territories/possessions. A manufactured-home or contract-for-deed label alone is insufficient.","S004 §2, “Federally related mortgage loan” (1)–(3), “State.”","R; no foreign-law or actual-product determination."],["R006-P1-C004","Primarily business, commercial, or agricultural credit is excluded under the relevant RESPA provisions; credit to government/agencies/instrumentalities is statutorily excluded.","Purpose is assessed under the specified Regulation Z interpretation, not simply a document’s “business loan” label.","S002 §2606(a)–(b); S005 §5(b)(2); S013 §3(a).","S/R/O; no actual purpose classification."],["R006-P1-C005","The temporary-financing exemption has operative qualifications.","It does not cover qualifying construction used as, convertible by the same lender to, or committed to permanent financing, or financing transfer to the first user. Qualifying construction of two years or more, except a bona fide builder loan, is covered. Bridge/swing financing is excluded as specified.","S005 §5(b)(3).","R; no universal “construction loan” result."],["R006-P1-C006","Other §5(b) exclusions are conditional.","Vacant/unimproved land: exception where proceeds will fund the specified structure/home within two years. Assumption: distinguish no lender approval right from required and obtained approval. Conversion: original-instrument-consistent changes without a required new note.","S005 §5(b)(4)–(6).","R; transaction facts remain unknown."],["R006-P1-C007","The secondary-market exemption expressly preserves §2605 and Subpart C.","Table-funded transactions and the specified initial dealer-loan transactions are not secondary-market transactions. Section 5(d)’s partial exemptions include §33(a), not a blanket exemption from §33(b)–(c).","S005 §5(b)(7), (d).","R; an ownership sale does not automatically escape servicing provisions."],["R006-P1-C008","Subpart C expressly excludes open-end home-equity plans; §33 has no general principal-residence restriction.","The principal-residence restriction in §30(c)(2) concerns §§39–41. Small-servicer, reverse-mortgage, and qualified-lender exemptions in §30(b) concern §§38–41, subject to their terms—not a blanket §33 exemption.","S007 §§30(b)–(c), 31 “Mortgage loan.”","R/O. The HELOC exclusion is regulatory wording, not an express phrase in §2605(b)–(d)."],["R006-P1-C009","A servicer is the person responsible for servicing, including a maker or holder that also services.","Servicing concerns receiving scheduled payments and making required onward payments; Regulation X includes payments to the borrower for reverse mortgages.","S001 §2605(i)(2)–(3); S004 “Servicer,” “Servicing.”","S/R; being an owner alone does not establish servicing."],["R006-P1-C010","Section 2605(i)(2) has named federal-actor exclusions.","FDIC/RTC specified asset or receivership/conservatorship functions; and the named Ginnie Mae/Fannie Mae/Freddie Mac/RTC/FDIC actors where the specified predecessor servicing termination, bankruptcy, or FDIC/RTC proceeding occurred.","S001 §2605(i)(2)(A)–(B).","S; statutory RTC wording is reported, not silently modernized."],["R006-P1-C011","Regulation X’s servicer exclusions must be read separately from the statutory list.","Specified FDIC functions; specified NCUA functions; and the named FNMA, Freddie Mac, FDIC, HUD—including GNMA/FHA—NCUA, Farm Service Agency, and VA actors in the enumerated cause-termination, bankruptcy, FDIC, or NCUA circumstances.","S004 “Servicer” (1)–(3).","R; government involvement or insurance alone does not establish an exclusion."],["R006-P1-C012","Master servicer, subservicer, transferor, and transferee are distinct functional definitions.","Master owns the servicing right; subservicer performs for the master without owning it. Transferor transfers, and transferee obtains, the right to perform servicing under an agreement/understanding. Specified table-funding brokers/dealers can be transferors.","S007 §31 definitions.","R; no blanket “mere subservicing” exemption follows."],["R006-P1-C013","The servicing effective date generally is the date payment is first due to the transferee pursuant to the servicing transfer.","For a HECM/reverse mortgage, §2 uses the transfer date agreed by the two servicers.","S001 §2605(i)(1); S004 “Effective date of transfer.”","S/R; not automatically sale, recording, letter, or receipt date."],["R006-P1-C014","A successor in interest here receives a qualifying interest in the secured property, not the creditor’s debt.","Five categories: specified death/survivorship transfers; relative after borrower’s death; spouse/children ownership; specified marital dissolution/separation/property settlement; qualifying inter vivos trust without occupancy-right transfer. Confirmation requires identity and property-interest confirmation by the servicer.","S007 §31; Successor comments 1–2.","R/O; trust beneficiaries, rather than the trust itself, are addressed by the trust comment."],["R006-P1-C015","A confirmed successor is treated as a borrower for the relevant Regulation X provisions without mandatory assumption.","That treatment does not determine contractual liability. Applicable obligations to the original borrower continue.","S007 §30(d), comments 1–3.","R/O; property succession is not debt acquisition by a covered person."],["R006-P1-C016","Section 32(c)’s optional notice-and-acknowledgment procedure can condition specified communications to a confirmed successor who is not liable.","Requires a compliant notice and separate acknowledgment limited to the permitted subjects: confirmation; nonliability/conditional security explanation; notice entitlement; request/understanding; no return deadline; and explanation of retained error, information, and payoff-request rights with addresses.","S008 §32(c)(1)(i)–(v).","R; merely saying “no assumption” does not establish this exception."],["R006-P1-C017","The successor communication limitations are narrow.","With a compliant procedure, specified disclosures may be withheld until assumption or acknowledgment; revocation has its stated effect. Copies must be available on oral/written request. Providing the same specific disclosure to another borrower can satisfy §32(c)(4).","S008 §32(c)(2)–(4), comments 32(c)(2)-1–2.","R/O; no blanket disappearance of successor or original-borrower rights."]]},{"headers":["Claim ID","Area and precise claim","Trigger, conditions, and exceptions","Source pinpoint","Status / limit"],"index":4,"links":[],"row_links":[[],[],[],[],[],[],[],[],[],[],[],[],[],[],[]],"rows":[["Claim ID","Area and precise claim","Trigger, conditions, and exceptions","Source pinpoint","Status / limit"],["R006-P1-C018","Ordinarily, both transferor and transferee owe a servicing-transfer notice.","A qualifying mortgage servicing assignment, sale, or transfer; apply coverage, actor, transfer, and successor exceptions first.","S001 §2605(b)(1), (c)(1); S009 §33(b)(1).","S/R; a change of debt owner is not required."],["R006-P1-C019","Three specified transfer categories are excluded only when all four listed payment features remain unchanged.","Affiliate transfer; merger/acquisition of servicers or subservicers; or master-servicer transfer without changing subservicer. Required unchanged features: payee, payment-delivery address, account number, and payment amount.","S009 §33(b)(2)(i)(A)–(C).","R; unchanged features alone do not create an additional unlisted category."],["R006-P1-C020","FHA has a specific notice exception when a National Housing Act-insured mortgage is assigned to FHA.","Applies to FHA’s stated duty; it is not a blanket exemption for every participant or every FHA-insured loan.","S009 §33(b)(2)(ii).","R; distinguish from the servicer-definition exclusions."],["R006-P1-C021","Ordinary clocks are transferor ≥15 days before; transferee ≤15 days after; combined servicing notice ≥15 days before.","Calendar days under §31. The transferee deadline does not require waiting until after transfer. No weekend/holiday exclusion or extra mailing days is stated for these clocks.","S001 §2605(b)(2)(A), (c)(2)(A); S007 “Day”; S009 §33(b)(3)(i).","S/R; no actual calendar calculation made."],["R006-P1-C022","The specified distress events permit notice no later than 30 days after the effective date.","Transfer must be preceded by servicing-contract termination for cause, commencement of servicer bankruptcy, specified FDIC proceedings, or specified NCUA proceedings. Statutory text separately names FDIC/RTC.","S001 §2605(b)(2)(B), (c)(2)(B); S009 §33(b)(3)(ii).","S/R; anticipated distress or ordinary inconvenience is not the stated trigger."],["R006-P1-C023","Compliant transfer notices at settlement satisfy the regulation’s timing requirement.","Separate or combined transferor/transferee notices under §33(b)(3)(iii). Statutory closing language refers to the loan maker providing the specified written notice.","S001 §2605(b)(2)(C), (c)(2)(C); S009 §33(b)(3)(iii).","S/R; no automatic settlement exception under §1026.39."],["R006-P1-C024","Regulation X disclosures generally must be clear, conspicuous, written, and retainable.","Electronic delivery is conditioned on E-Sign consumer consent and other applicable requirements. Foreign-language disclosures must be available in English on request. Combination is permitted unless prohibited by applicable law or specified regulatory agreement.","S008 §32(a)–(b).","R; an email’s existence does not establish compliant electronic delivery."],["R006-P1-C025","For mailing under Regulation X, placing correctly addressed material in the mail can satisfy the mailing requirement whether or not received.","Use §11 and transfer comment 33(b)(3)-1: appropriate borrower address(es), including a qualifying notified change. A notice’s printed date alone does not prove dispatch.","S006 §11; S009 comment 33(b)(3)-1.","R/O; the last sentence is I. Actual payment receipt uses a different test."],["R006-P1-C026","The servicing notice must disclose the effective date and usable contacts for both servicers.","For each servicer, §33(b)(4)(ii)–(iii) specifies employee/department name, address, and toll-free or collect-call telephone number for transfer inquiries. Statutory subparagraphs separately identify the transferee and contacts.","S001 §2605(b)(3)(A)–(D), (c)(3); S009 §33(b)(4)(i)–(iii).","S/R; ownership identification is a separate regime."],["R006-P1-C027","Remaining required servicing content concerns acceptance dates, optional insurance, and unchanged nonservicing terms.","Old stop/new start acceptance dates must be the same or consecutive days; disclose optional-insurance effects and necessary preservation actions; state transfer does not affect terms other than directly servicing-related terms.","S001 §2605(b)(3)(E)–(G); S009 §33(b)(4)(iv)–(vi).","S/R; statutory wording concerns security instruments; regulation refers to mortgage-loan terms."],["R006-P1-C028","Current MS-2 also includes a payment-address instruction and a 60-day protection paragraph.","Those model passages must be distinguished from §33(b)(4)’s enumerated content. The final-rule explanation retained them without making every model sentence an independent enumerated requirement.","S010 MS-2; S017 pp.10732, 10839; S011 pp.752–753.","R/H; omission is not automatically classified solely by model comparison. Operative “beginning” controls over the model’s “following” wording."],["R006-P1-C029","MS-2 is optional; appropriate use has the stated disclosure-compliance protection.","Required information still must be supplied. Permissible changes must preserve substance, clarity, and meaningful sequence; inapplicable content may be removed. Successor wording may avoid implying personal liability.","S010/S011 Appendix MS comments 1–2, including 2(iv)(A)–(C).","O; no actual notice compliance or broader immunity found."],["R006-P1-C030","The application-stage servicing disclosure is separate from an actual transfer notice.","Current §33(a) applies to reverse-mortgage applications; its three-day period excludes legal public holidays, Saturdays, and Sundays; timely denial is an exception. Section 2’s general business-day definition is not substituted for this express exclusion.","S009 §33(a), comments 1–3; S007 §30(c)(1); S004 “Business day.”","R/O; MS-1 and MS-2 serve different events."],["R006-P1-C031","The preemption provisions concern the specified notice requirements; they do not resolve all state-law issues.","§2605(h), §33(d), and §5(c) must be read together. Section 33(d) preserves specified notices to insurance companies or taxing authorities.","S001 §2605(h); S005 §5(c); S009 §33(d).","S/R/O; state title, assignment, contract, and other law remain held."]]},{"headers":["Claim ID","Area and precise claim","Trigger, conditions, and exceptions","Source pinpoint","Status / limit"],"index":5,"links":[],"row_links":[[],[],[],[],[],[],[]],"rows":[["Claim ID","Area and precise claim","Trigger, conditions, and exceptions","Source pinpoint","Status / limit"],["R006-P1-C032","The protection concerns a payment received by the transferor during the 60-day period beginning on the servicing effective date.","Statute says receipt before the applicable due date; regulation says on or before, including a grace period allowed by the loan instruments. Apply the regulation’s actual wording rather than silently paraphrasing the two texts as identical.","S001 §2605(d); S009 §33(c)(1); S011 §33.","S/R; begins with the transfer event, not notice receipt."],["R006-P1-C033","A qualifying payment may not be treated as late for any purpose; late fees are included.","This does not establish an account-wide credit-reporting freeze, protection for unrelated unpaid installments, or general immunity. Comment 33(c)(1)-2 says compliance with §1024.39 during the period is not itself prohibited late treatment.","S009 comments 33(c)(1)-1–2; S001 §2605(d), distinguished from (e)(3).","S/R/O; broader reporting/remedies questions held."],["R006-P1-C034","Beginning on the effective date, the old servicer must promptly forward an incorrectly received payment or return it and notify the payor of the proper recipient.","Forwarding must be to the transferee for account application. Return must be to the person who paid, with the recipient notification. The clause states no numerical “promptly” deadline, no express 60-day end, and no specified written form for that notification.","S009 §33(c)(2)(i)–(ii); S017 p.10733.","R/H; do not invent a forward-only duty or fixed number of days."],["R006-P1-C035","Inclusion of an instrument-authorized grace period in this protection does not itself amend the contractual due date, principal, rate, or amount.","Official delinquency commentary distinguishes a due-and-unpaid installment from a later late-fee assessment date. The transfer provision controls the specified treatment of qualifying misdirected payments.","S007 Delinquency comment 1; S009 §33(b)(4)(vi), (c)(1).","O/R plus I; actual contract and accrual remain held."],["R006-P1-C036","Sending, scheduling, or postmarking a payment is not the same factual proposition as old-servicer receipt.","Relevant predicates include actual recipient and receipt time, transfer effective date, applicable due/grace terms, and which payment the receipt concerns.","S009 §33(c)(1)–(2).","I from the receipt wording; unknown receipt stays U."],["R006-P1-C037","A partial payment must not be treated as proof that a full installment was satisfied.","Do not categorically erase the misdirection protection merely because a payment was partial; separately determine what was received and what remained unpaid. The payment-tolerance comment applies if the servicer elects the specified treatment.","S007 §31 “Delinquency,” comments 1–3; S009 §33(c); S014 §39(d)(5).","I/O; allocation, sufficient-payment treatment, and actual shortfall remain U/held."]]},{"headers":["Claim ID","Area and precise claim","Trigger, conditions, and exceptions","Source pinpoint","Status / limit"],"index":6,"links":[],"row_links":[[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[]],"rows":[["Claim ID","Area and precise claim","Trigger, conditions, and exceptions","Source pinpoint","Status / limit"],["R006-P1-C038","Section 1641(g) requires the new owner/assignee to give a written ownership-transfer notice within its stated 30-day period.","Statutory mortgage definition: consumer credit secured by the consumer’s principal dwelling. Content: new creditor identity/contact, transfer date, authorized contact, recording location, and relevant additional information.","S003 §1641(g)(1)–(2).","S; separate from servicing notice."],["R006-P1-C039","Current §39’s closed-end coverage is broader than the statute’s stated principal-dwelling definition.","Open-end: principal dwelling. Closed-end: dwelling or real property. Posted comment 39(a)(2)-1 still describes principal-dwelling coverage; amended text, comment 39(d)-2, and the final amendment establish the broader closed-end wording.","S014 §39(a)(2), comments 39(a)(2)-1 and 39(d)-2; S018 p.80130; S016.","R/O/H; discrepancy disclosed, not silently reconciled by narrowing the rule."],["R006-P1-C040","Consumer, dwelling, and person are distinct definitions.","Consumer credit is primarily personal/family/household. A dwelling can be a qualifying residential structure without real-property status. A covered owner can be an organization; an organizational purchaser does not thereby turn the borrower’s loan into organizational credit.","S013 §2(a)(11), (12), (19), (22), comments.","R/O; last sentence I."],["R006-P1-C041","Business-purpose and organizational-credit exclusions require the correct borrower/transaction analysis.","Section 3(a) applies; necessary trust interpretations prevent treating every trust transaction as automatically excluded.","S013 §3(a)(1)–(2), relevant comments; §2(a)(11) comments.","R/O; no actual consumer/business or trust determination."],["R006-P1-C042","A §39 covered person acquires legal title to an existing mortgage debt and acquires more than one mortgage loan in any twelve-month period.","Purchase, assignment, or other transfer can qualify; the person need not satisfy Regulation Z’s separate “creditor” definition. Partial and joint legal-title acquisitions can qualify.","S014 §39(a)(1), comments 1–2.","R/O; acquisition frequency and actual legal title are not presumed."],["R006-P1-C043","Beneficial interest, a security interest, or credit risk without legal title does not satisfy the legal-title trigger.","Administrative-convenience assignment to a servicer is also excluded as specified.","S003 §1641(f)(1)–(3); S014 §39(a)(1), comment 3.","S/R/O; securitization or servicing labels alone do not decide the issue."],["R006-P1-C044","Affiliation does not itself excuse an ownership disclosure.","Acquisition by a separate legal entity, including through a qualifying merger, acquisition, or reorganization, is addressed by the ownership rule, subject to its other conditions.","S014 comments 39(a)(1)-2(iii), -4.","O; do not import the Regulation X affiliate exception."],["R006-P1-C045","The owner must mail or deliver by the 30th calendar day following its defined transfer date.","The covered person may use acquisition recognized in its books or transfer recognized in the transferor’s books. No business-day exclusion, holiday extension, or extra presumed receipt period is stated here.","S014 §39(b), (b)(2); S016.","R; notice date or recording date is not freely substituted."],["R006-P1-C046","Ownership disclosures must be clear, conspicuous, written, and retainable; electronic provision is E-Sign-conditioned.","With multiple liable consumers, delivery to any primarily liable consumer is permitted by §39(b)(3). Combining with servicing notices is allowed only if applicable requirements are met.","S014 §39(b)(1), (3), comment 39(b)(1)-1.","R/O; do not import this recipient rule into §33."],["R006-P1-C047","Disposition of all acquired interest by the 30th calendar day can exempt that intermediate acquirer.","Retention of a partial interest on that day prevents reliance on this particular exception. The next acquirer requires its own analysis.","S014 §39(c)(1), comments 1–2.","R/O; no chain-wide exemption."],["R006-P1-C048","A qualifying repurchase agreement can excuse disclosure while its specified arrangement applies.","The transferor must be obligated to repurchase. If repurchase does not occur, the covered person must disclose within 30 days after recognizing acquisition on its books; the interpretation also addresses intermediaries.","S014 §39(c)(2), comment 1.","R/O; not every temporary holding or warehouse arrangement qualifies."],["R006-P1-C049","The partial-interest exception requires both a partial acquisition and no specified authorized-contact change.","The party authorized to receive rescission notice and resolve payment issues must remain unchanged as a result of the transfer. Same servicer alone does not establish the exception; acquisition of the remaining interest is separately addressed by the comment.","S014 §39(c)(3), comments 1–2.","R/O; no general “same servicer” exemption."],["R006-P1-C050","For sequential acquisitions, one disclosure for multiple covered persons is optional if each person’s requirements are met.","Each retains its compliance duty. A subsequent transfer date may be estimated only under the comment’s unknown/reasonably-available, good-faith diligence standard.","S014 §39(b)(4), comments 1–3.","R/O; no invented actual dates."],["R006-P1-C051","Joint acquisition requires a single disclosure for the joint covered persons.","Where completion dates differ, the comment uses the earliest acquisition’s clock. Separate, unrelated partial acquisitions are different: each duty remains, although a compliant combined disclosure is possible.","S014 §39(b)(5), comments 1–4; 39(a)(1)-2(ii).","R/O; “multiple owners” does not by itself establish joint acquisition."],["R006-P1-C052","The notice must identify the transferred loan and provide the covered owner’s name, address, telephone number, and transfer date.","Loan identification must be sufficient under the comment; no actual or invented identifying value is entered here. Servicer contact alone is not ordinarily a substitute for owner identification.","S014 §39(d), (d)(1)–(2), comments 39(d)-1 and 39(d)(1)-1.","R/O."],["R006-P1-C053","A combined notice ordinarily identifies each covered person; a narrow authorized-owner exception can permit identification of only one.","The identified party must itself be a covered person authorized for both specified rescission and payment functions.","S014 §39(d)(1)(i)–(ii), corresponding comments.","R/O; identifying any servicing agent is not equivalent."],["R006-P1-C054","The authorized-contact disclosure concerns receiving rescission notices and resolving payment issues.","Owner contact can suffice if usable for those purposes. If multiple agents are listed, their differing authority must be explained. No new agent need be appointed; email/website are optional.","S014 §39(d)(3), comments 1–2.","R/O; this content requirement does not create an otherwise absent rescission right."],["R006-P1-C055","The recording disclosure permits the stated alternatives.","Disclose where ownership transfer is or may be recorded, or truthfully that it has not been recorded when notice is provided. The comment does not require an exact street address.","S014 §39(d)(4), comment 1.","R/O; neither recording nor validity is established by the notice’s assertion."],["R006-P1-C056","Applicable closed-end notices must disclose the partial-payment policy under the specified heading.","Excludes reverse mortgages from this additional content, not automatically the entire ownership rule. State the applicable accept/apply, accept/hold-until-complete, or reject policy; include that a later lender may have a different policy.","S014 §39(d) introductory text, (d)(5)(i)–(iv); S018 p.80130.","R; a policy disclosure is not an adjudication of lawful payment application."],["R006-P1-C057","Old application dates do not create a perpetual exclusion from §39(d)(5).","The official implementation commentary addresses October 3, 2015 transition treatment and conditions occurring on or after October 1, 2018, regardless of application date.","S015 comment 1(d)(5)-1, especially post-consummation provisions.","O; no individual deadline calculated."],["R006-P1-C058","Regulation Z includes confirmed-successor treatment and a specified notice/acknowledgment limitation.","Apply §2(a)(11), (27) and §39(f)’s actual wording, including the compliant Regulation X notice, nonliability, assumption, acknowledgment, and revocation conditions.","S013 relevant successor definitions/comments; S014 §39(f); S019 instruction 22.","R/O; not a general owner exemption or determination of personal liability."],["R006-P1-C059","Transmission on another covered person’s behalf is contemplated; substantive responsibility is not erased.","Current multiple-person provisions expressly allocate duties; the 2013 explanation contemplates owner/servicer arrangements for required disclosure. A sender’s letterhead alone proves neither ownership nor authority nor compliance.","S014 §39(b)(4)–(5), duty comments; S018 pp.80059–80060.","R/O; broader agent-delivery conclusion is bounded I. Actual agency is U."],["R006-P1-C060","A contact change alone, without qualifying acquisition, is not the §39 ownership-transfer trigger.","Conversely, a qualifying partial transfer plus change of the specified authorized party can defeat §39(c)(3)’s exception. Other contact-update duties are outside this component.","S014 §39(a), (c)(3), (d)(3), (e).","I from the stated trigger; no general exemption from other law."],["R006-P1-C061","These disclosure provisions do not make a notice conclusive proof of assignment, title, security rights, balance, or standing.","Likewise, absence or defect of notice does not itself establish invalid assignment, debt cancellation, or a remedy. Distinct substantive and evidentiary law would be needed.","S001 §2605(b)–(d); S003 §1641(g); S014 §39(a), (d).","Expressly bounded I; all actual legal-status and litigation questions held."]]},{"headers":["Claim ID","Precise claim","Source pinpoint","Status / limit"],"index":7,"links":[],"row_links":[[],[],[],[],[],[]],"rows":[["Claim ID","Precise claim","Source pinpoint","Status / limit"],["R006-P1-C062","Current MS-2 retains the short payment-transition protection paragraph. Historical complaint-resolution/QWR language and proposals discussed in the 2013 preamble are not imported as current required transfer-notice content.","S010–S012; S017 pp.10730–10733, 10839.","H/R/O; current text controls; no historical full-form reconstruction claimed."],["R006-P1-C063","Agency “current” labels and House compilation dates do not establish a complete through-today legal audit. Direct eCFR and 2026 annual §39 body gaps remain.","S001–S003, S016, S022–S024.","U as to exhaustive currency; substantive retrieved text identified precisely."],["R006-P1-C064","Relevant implementation dates are separate from access dates: §1641(g)’s May 20, 2009 statutory event; 2013 servicing rule’s January 10, 2014 effective date; successor provisions’ April 19, 2018 effective date; partial-payment transition in C057.","S003, S015, S017, S019–S020.","S/H/O. The 2010 former-rule effective-date discrepancy is not resolved or used to decide a historical transaction."],["R006-P1-C065","The posted §31 page’s COVID definition is stale relative to the 2025 removal and 2026 annual CFR. The relevant day, servicing, mortgage-loan, and successor definitions were separately checked.","S007; S011 §§30–31; S021 instruction 2.","R/H; this finding does not reopen COVID servicing or foreclosure law."],["R006-P1-C066","No actual transfer date, receipt date, contractual payment deadline, amount, or individual compliance result has been established.","Assignment limits; C013, C021–C023, C032, C045.","U by design. All periods remain event-triggered; no actual-calendar arithmetic performed."]]},{"headers":["Proposition to establish","Necessary evidence category, described generically","What does not establish it by itself"],"index":8,"links":[],"row_links":[[],[],[],[],[],[],[],[],[]],"rows":[["Proposition to establish","Necessary evidence category, described generically","What does not establish it by itself"],["Applicable loan and actor coverage","Product, purpose, collateral/nexus, servicing-role facts, and any claimed exception","“Mortgage,” “secured,” “bank,” “small servicer,” or “business” as an unexplained label"],["Servicing effective date","The event satisfying §2605(i)(1), or the reverse-mortgage agreed-date rule","Ownership sale date, recording date, notice date, or date the borrower learned of the transfer"],["Receipt by the old servicer","Evidence of actual receipt by that recipient and when it occurred","Mailing a check, scheduling bill pay, an instruction to an intermediary, or an unsupported assertion of receipt"],["Applicable payment deadline","Relevant due-date and grace-period provisions of the governing instruments","A general expectation that all loans have the same grace period"],["Which payment was received","Sufficient reconciliation of the receipt to the payment obligation and amount tendered","Assuming every receipt paid the entire installment or cured earlier arrears"],["Prohibited late treatment","The actual fee or classification, its basis, and its relationship to the qualifying payment","The mere existence of a transfer, account delinquency, or a later communication"],["Compliance with forwarding/return","Receipt chronology, onward transfer or return, and recipient notification where returned","A notice saying the old servicer will stop accepting payments"],["Notice timeliness","Actual mailing/delivery evidence, proper address/method, and the correct event clock","Only the date printed on the notice or the consumer’s nonreceipt"]]},{"headers":["Example","Stipulated hypothetical facts","Statute/regime-specific result versus unknown","Evidence category needed to resolve the unknown—not a records request","Adverse misclassification to avoid"],"index":9,"links":[],"row_links":[[],[],[],[],[],[],[],[],[],[],[],[],[],[],[]],"rows":[["Example","Stipulated hypothetical facts","Statute/regime-specific result versus unknown","Evidence category needed to resolve the unknown—not a records request","Adverse misclassification to avoid"],["E01 — Servicing only","A covered loan’s servicing transfers; debt ownership remains unchanged; no transfer exception is stipulated.","Analyze both §33 notices and payment-transition rules. An ownership notice is not triggered merely by that stipulated servicing event. C018–C037, C042.","Actual servicing effective date, dispatch/content, exception facts, and payment receipt if relevant.","Treating the new servicer as necessarily the new debt owner."],["E02 — Ownership only, same servicer","A qualifying covered person acquires full legal title; the existing servicer continues; no ownership exception applies.","§39 disclosure is implicated despite unchanged servicing. The acquisition alone does not start §33’s servicing-transfer protection. C038–C049.","Acquisition recognition, covered-person frequency, and notice dispatch/content.","Assuming “same servicer” eliminates ownership disclosure."],["E03 — Both transfers; one late combined letter","Both events occur; the only combined letter is sent after the servicing effective date; no special servicing timing exception is stipulated.","That timing cannot satisfy the ordinary combined servicing notice requirement. Ownership timing/content require their own analysis; a timely ownership disclosure does not cure the servicing timing problem. C021–C023, C045–C046.","Separate event clocks, actual dispatch, and full content.","Treating one envelope as automatic satisfaction of both regimes."],["E04 — Claimed timely old-servicer receipt","The payer asserts that the former servicer received the payment within the protected period and by the applicable deadline; receipt is not independently stipulated.","Protection is conditional; the assertion alone leaves the receipt predicate unknown. If established, C032–C033 supply the treatment rule.","Actual receipt time/recipient, instrument deadline/grace, and treatment of that payment.","Declaring a prohibited late fee solely from the payer’s claim."],["E05 — Sent, receipt unknown","Payment was sent toward the old servicer; actual recipient and receipt date are unknown.","Sending does not establish §33(c)(1). Section 33(c)(2)’s handling duty likewise depends on receipt by the transferor. C034, C036.","Delivery/receipt chronology and any return.","Replacing receipt with postmark, scheduling date, or intent."],["E06 — Partial payment","The old servicer receives less than the full installment within the relevant period and deadline.","Do not assume full satisfaction; do not categorically disregard the misdirection protection. Treatment of the received payment and any unpaid remainder are separate questions. C037, C056.","Amount received relative to the installment, tolerance treatment, applicable policy, and application/return facts.","Calling a short installment fully cured, or denying all protection merely because it was partial."],["E07 — Product branch unresolved","The product might be an open-end home-equity plan, consumer closed-end mortgage, or primarily business-purpose credit; classification is not stipulated.","Coverage is unresolved. A principal-dwelling HELOC is excluded by Regulation X Subpart C’s definition but can fall within §39’s ownership definition. No broader statutory-claim decision follows here. C004, C008, C039–C041.","Product structure, purpose, security, federal nexus where required.","Applying one mortgage regime to every secured product."],["E08 — Subservicing branch unresolved","A servicing arrangement changes, but the master/subservicer functions and changes in the four payment features are unknown.","No automatic exemption or duty finding. Test the actual §33(b)(2)(i) category and every condition. C012, C019.","Functions transferred; qualifying affiliation/merger/master relationship; four payment features.","Assuming every subservicer change is exempt—or every internal change necessarily triggers notice."],["E09 — Sequential ownership transfers","An intermediate covered acquirer disposes of all its interest within the stated 30-day exception period.","That acquirer may use §39(c)(1); the next acquirer needs its own analysis. If the intermediate retains an interest, the stated exception does not follow. C047, C050.","All-interest disposition, recognition dates, retained interest, and subsequent acquirer’s conditions.","Extending one intermediary’s exception through the whole chain."],["E10 — Joint owners and agent delivery","Multiple covered persons jointly acquire; an authorized sender transmits one disclosure on their behalf.","Joint-acquisition single-notice and earliest-clock rules apply. Owner identification and the narrow authorized-owner exception still matter; sender identity does not erase duties. C051–C054, C059.","Joint agreement character, dates, owners identified, scope of authorization, dispatch/content.","Equating the agent with the owner or using the latest acquisition date automatically."],["E11 — Contact change alone","The debt owner and servicer remain the same; only contact details change; no acquisition occurs.","The stipulated change alone is not §39’s acquisition trigger. Other contact-update rules remain held. A partial acquisition plus authorized-party change would be a different branch. C049, C060.","Whether an acquisition actually occurred and what authority changed.","Treating every address change as ownership transfer, or treating contact changes as irrelevant to the partial-interest exception."],["E12 — Confirmed property successor","A qualifying property successor is confirmed but has not assumed personal liability.","Borrower/consumer treatment and the precise acknowledgment provisions apply. Property succession is not acquisition of the creditor’s debt. C014–C017, C058.","Qualifying succession, confirmation, liability status, compliant notice/acknowledgment, and any revocation.","Converting receipt of notices into debt assumption or creditor ownership."],["E13 — Receipt outside the 60-day window","The old servicer incorrectly receives a payment after the protected 60-day period.","Section 33(c)(1)’s period cannot simply be extended. Section 33(c)(2) has no express 60-day cutoff and still requires its own handling analysis. C032, C034.","Actual effective date, receipt, forwarding/return chronology, and notification.","Ending every transfer-related handling duty at day 60."],["E14 — Claimed emergency or settlement exception","A party invokes “emergency transfer” or says “notice was handled at closing,” without the qualifying facts stipulated.","The label does not establish the specified timing exception. Ownership notice timing remains separate. C022–C023, C045.","Enumerated preceding event or compliant settlement notices, plus dispatch/content.","Turning a narrow timing exception into a blanket notice exemption."]]},{"headers":["Audit item","Blank response","Governing reference"],"index":10,"links":[],"row_links":[[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[]],"rows":[["Audit item","Blank response","Governing reference"],["Consumer/open-end/closed-end/reverse product classification established?","________","C003–C008, C039–C041"],["Necessary purpose and collateral conditions established?","________","C002–C006, C040–C041"],["Regulation X federal nexus established where required?","________","C002–C003"],["Statutory/regulatory actor exclusions considered separately?","________","C009–C011"],["Servicing transfer, debt-title transfer, property succession, or more than one event?","________","C001, C012–C015, C042"],["Master/subservicer functions distinguished?","________","C012"],["Exact conditional transfer exclusion identified, if any?","________","C019–C020"],["All four unchanged-payment conditions tested where required?","________","C019"],["Servicing effective-date basis identified, without entering a date?","________","C013"],["Transferor, transferee, separate, or combined servicing notice?","________","C018, C021"],["Ordinary, specified extended, or settlement timing branch?","________","C021–C023"],["Mailing/delivery act distinguished from printed date and receipt?","________","C024–C025"],["Correct address(es)/change-of-address rule tested?","________","C025"],["Effective date and both required servicing contacts disclosed?","________","C026"],["Stop/start payment acceptance dates compatible?","________","C027"],["Optional-insurance effects/actions addressed as applicable?","________","C027"],["Required nonservicing-terms statement present?","________","C027"],["Model-only language distinguished from enumerated requirements?","________","C028–C030"],["Actual old-servicer payment receipt established?","________","C032, C036"],["Applicable due/grace terms and 60-day window distinguished?","________","C032, C035"],["Full/partial payment and remaining shortfall kept separate?","________","C037"],["Prompt forwarding or return-plus-notification analyzed?","________","C034"],["Ownership covered-person legal-title/frequency conditions established?","________","C042–C044"],["Ownership transfer-date recognition basis identified?","________","C045"],["Each ownership exception tested on all conditions?","________","C047–C049"],["Sequential versus joint acquisitions distinguished?","________","C050–C051"],["Loan sufficiently identified, without copying any identifying value here?","________","C052"],["Owner identification and any narrow multiple-owner exception tested?","________","C052–C053"],["Agent functions and differing authority explained?","________","C054, C059"],["Recording disclosure matches an allowed, truthful alternative?","________","C055"],["Applicable partial-payment policy content included?","________","C056–C057"],["Confirmed-successor/acknowledgment provisions relevant and satisfied?","________","C014–C017, C058"],["Combined document separately satisfies each applicable regime?","________","C021, C024, C046"],["Notice conclusions kept separate from assignment/title/balance/standing conclusions?","________","C061"],["Unresolved facts and source-currentness/image gaps explicitly retained?","________","C063, C065–C066"]]},{"headers":["Assigned subquestion / major branch","Status","Claim / example links","Exact missing authority or facts","Next bounded permissible investigation"],"index":11,"links":[],"row_links":[[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[]],"rows":[["Assigned subquestion / major branch","Status","Claim / example links","Exact missing authority or facts","Next bounded permissible investigation"],["§2605(b) transferor duty/content","A","C018, C021–C027","Actual coverage/event/notice facts absent","None needed for the stated generic rule"],["§2605(c) transferee duty/content","A","C018, C021–C027","Same","Same"],["§2605(d) payment protection","A/U","C032–C037; E04–E06","Actual receipt, deadline, payment and treatment facts","None without changing the no-record scope"],["Statutory FRML definition","A","C002","Actual collateral/nexus","Further generic definition authority only if a new product question is authorized"],["§2606 purpose/government exclusions","A/U","C004","Actual purpose and recipient category","No factual classification undertaken"],["§1024.2 necessary definitions","A","C003, C009–C013","Actual role and product facts","None for stated branches"],["Temporary/construction/bridge exclusions","A/U","C005","Financing structure, term, builder/permanent-finance conditions","No actual-product investigation"],["Vacant-land exclusion and exception","A/U","C006","Use of proceeds and construction/placement conditions","Same"],["Assumption and conversion exclusions","A/U","C006","Approval right/permission; original terms/new note","Contract work held"],["Secondary-market carveback","A","C007","Actual transaction character","None for the statutory/regulatory distinction"],["Partial exemptions under §5(d)","A","C007","Whether a specific transaction meets them","No general TRID gateway rerun"],["§30 small-servicer/reverse/qualified-lender limits","A","C008; E07","Actual exemption status not determined","None needed to show these are not blanket §33 exemptions"],["Principal residence versus broader §33 scope","A","C008","Actual product/property facts","No property investigation"],["Open-end product divergence","A/P","C008, C039; E07","Any broader direct statutory-claim issue is not adjudicated","If later authorized, examine public authority on that precise statutory/regulatory issue"],["Servicer versus master/subservicer","A/U","C009, C012, C019; E08","Actual functions/agreement and payment changes","Generic authority only; no provider investigation"],["Statutory and regulatory named-actor exclusions","A/U","C010–C011","Applicable actor/function/distress facts","No entity-status query"],["Confirmed successor definition","A/U","C014–C015; E12","Qualifying transfer and confirmation","No property/identity investigation"],["Successor acknowledgment exceptions","A/U","C016–C017, C058; E12","Compliance, assumption, acknowledgment/revocation facts","None for generic conditions"],["Both servicers’ duties","A","C018; E01","Actual notice performance","No records work"],["Affiliate/merger/master exclusions","A/U","C019; E08","Listed category and all four unchanged features","No corporate investigation"],["FHA-specific notice exception","A/U","C020","Exact assignment/actor facts","No loan/provider investigation"],["Separate and combined servicing clocks","A","C021; E03","Actual event and dispatch dates","Keep triggered periods; no calendar invented"],["Extended timing events","A/U","C022; E14","Enumerated preceding event","No bankruptcy/corporate/docket query"],["Settlement timing","A/U","C023; E14","Compliant settlement notice facts","No closing-document request"],["Mailing versus receipt","A/U","C024–C025; E04–E05","Actual dispatch, addresses, electronic conditions","No evidence collection"],["Business/calendar-day distinctions","A","C021, C030, C045","No dates supplied","No arithmetic needed"],["Required payment/contact/address/effective-date content","A","C026–C028","Actual document text absent","Blank audit supplied"],["Current MS-2 complete text","A","C028–C029, C062","None as to parsed model text","None needed for text identification"],["MS-2 pixel/layout inspection","P","S011–S012; failure log","Inspectable image content was not exposed by screenshot responses","Obtain inspectable images of only the two official model pages through an authorized public-web capability"],["Historical/proposed model distinction","A/P","C030, C062","No complete historical form reconstruction attempted","Only if a historical-version question becomes necessary"],["60-day trigger versus notice date","A","C013, C032","Actual effective date","No actual calculation"],["Late-fee/late-treatment restriction","A/U","C033","Particular fee/classification and payment linkage","Full reporting/remedy work held"],["Forwarding/return and recipient notification","A/U","C034; E13","Receipt/handling/notification facts; contextual promptness","Generic authority on “promptly” only if a later narrow question requires it"],["Grace period versus contract modification","A/U","C035","Actual contractual terms","Contract analysis held"],["Sent-but-unreceived payment","A/U","C036; E05","Receipt unknown","Retain unknown"],["Partial payment","A/U","C037; E06","Shortfall, policy, tolerance, application","Full payment-crediting/accounting analysis held"],["§1641(g) statute and §39 product difference","A","C038–C041","No actual product facts","None for text comparison"],["Posted §39 scope-comment inconsistency","A/P","C039","Complete publisher correction history not audited","Check official correction/amendment publications if needed"],["Covered person/legal-title/frequency","A/U","C042","Actual title acquisition and acquisition frequency","No owner/entity/loan roster investigation"],["Beneficial/security interest and administrative convenience","A/U","C043","Actual interest acquired and purpose","Assignment/title work held"],["Ownership affiliate/merger branch","A/U","C044","Different-entity acquisition facts","No corporate-record query"],["Ownership timing and date election","A/U","C045","Recognized acquisition/transfer date","No books-and-records request"],["Ownership recipient/form/combination","A/U","C046","Actual liable-recipient and delivery facts","No individualized compliance finding"],["All-interest disposition exception","A/U","C047; E09","Retained/disposed interest and timing","No chain-of-title investigation"],["Repurchase exception","A/U","C048","Repurchase obligation and recognition facts","Generic contract-law expansion held"],["Partial-interest/no-contact-change exception","A/U","C049; E11","Interest and authorized-party changes","No provider/agency investigation"],["Sequential transfers","A/U","C050; E09","Sequence, timing, availability of future-date information","No record search"],["Joint acquisitions","A/U","C051; E10","Same agreement/concert, completion dates","No transaction-record search"],["Owner/agent/recording content","A/U","C052–C055, C059","Actual notice, agency authority, recording facts","No recording search or identifiers"],["Partial-payment disclosure and transition dates","A","C056–C057","Actual applicable policy unknown","No full payment-processing review"],["Contact change without acquisition","A","C060; E11","Stipulated in example; actual event unknown","Other update duties held"],["Notice versus assignment/security/standing proof","A/X","C001, C061","Substantive documents and applicable law intentionally absent","Parent-held investigation; not authorized here"],["Full current-law/session-law lag audit","P","C063–C065; S023–S024","Direct eCFR bodies; verified 2026 annual §39; complete post-compilation update audit","Retrieve official current bodies and bounded amendment/correction history"],["Hypothetical branches","A","E01–E14","No individual facts intended","None"],["Blank audit worksheet","A","Section 6","All entries deliberately blank","None"],["Cases/opinions","X","Read log","No material opinion necessary for this text-focused component","Published majority opinion only if a later narrow legal issue strictly requires it"],["State/local/tribal/foreign/product/contract closure","X","C031, C061; parent holds","All jurisdictional and actual-contract predicates absent","Separate authorization and bounded scope required"],["Eligibility, liability, remedies, litigation decision","X","C061, C066","Not investigated or decided","Remains parent-held"]]},{"headers":["Log item","What actually happened","Effect on the report"],"index":12,"links":[{"href":"https://uscode.house.gov/view.xhtml?req=granuleid:USC-prelim-title12-section2605&num=0&edition=prelim","text":"https://uscode.house.gov/view.xhtml?req=granuleid:USC-prelim-title12-section2605&num=0&edition=prelim"},{"href":"https://uscode.house.gov/view.xhtml?req=granuleid:USC-prelim-title15-section1641&num=0&edition=prelim","text":"https://uscode.house.gov/view.xhtml?req=granuleid:USC-prelim-title15-section1641&num=0&edition=prelim"},{"href":"https://www.federalregister.gov/documents/2024/07/24/2024-15475/streamlining-mortgage-servicing-for-borrowers-experiencing-payment-difficulties-regulation-x?utm_source=chatgpt.com","text":"https://www.federalregister.gov/documents/2024/07/24/2024-15475/streamlining-mortgage-servicing-for-borrowers-experiencing-payment-difficulties-regulation-x"}],"row_links":[[],[{"href":"https://uscode.house.gov/view.xhtml?req=granuleid:USC-prelim-title12-section2605&num=0&edition=prelim","text":"https://uscode.house.gov/view.xhtml?req=granuleid:USC-prelim-title12-section2605&num=0&edition=prelim"},{"href":"https://uscode.house.gov/view.xhtml?req=granuleid:USC-prelim-title15-section1641&num=0&edition=prelim","text":"https://uscode.house.gov/view.xhtml?req=granuleid:USC-prelim-title15-section1641&num=0&edition=prelim"}],[],[],[],[],[],[],[],[],[{"href":"https://www.federalregister.gov/documents/2024/07/24/2024-15475/streamlining-mortgage-servicing-for-borrowers-experiencing-payment-difficulties-regulation-x?utm_source=chatgpt.com","text":"https://www.federalregister.gov/documents/2024/07/24/2024-15475/streamlining-mortgage-servicing-for-borrowers-experiencing-payment-difficulties-regulation-x"}],[],[],[]],"rows":[["Log item","What actually happened","Effect on the report"],["F01 — Initial House routes failed","Legacy routes, including https://uscode.house.gov/view.xhtml?req=granuleid:USC-prelim-title12-section2605&num=0&edition=prelim and https://uscode.house.gov/view.xhtml?req=granuleid:USC-prelim-title15-section1641&num=0&edition=prelim, failed. New publisher routes in S001–S003 subsequently supplied the necessary bodies.","Recovered, with exact compilation dates preserved. Earlier failures are not evidence of missing statutes."],["F02 — Direct eCFR failed","The four section URLs in S023 did not yield operative bodies.","Unresolved retrieval gap, mitigated by annual CFR, agency text, and final-rule reads."],["F03 — Annual Regulation Z edition","The 2026 §39 URL in S024 failed; the most-recent link returned the 2025 edition.","No claim that the 2026 edition does not exist; no claim that 2025 alone proves current law."],["F04 — Model retrieval boundaries","A one-page appendix granule was initially available. Full-part retrieval supplied the continuation, so complete MS-2 text was read. The 2026 model is at pp.752–753, not the 2025 pp.754–755.","No claim that an isolated first page was the full notice."],["F05 — Screenshot limitation","One earlier screenshot timed out; later requests reported image-display markers. Inspection of the returned structure showed text markers without image blocks available for visual review.","Parsed text is not pixels. No unseen full-form or layout claim is made."],["F06 — Other recovered routes","Capitalized CFPB model URL failed; the actual lowercase /ms2/ route worked. An attempted 2013 TRID PDF route failed; official GovInfo HTML supplied the necessary full clauses and printed-page markers.","Recovered text reads; no claim to have inspected the failed PDF’s images."],["F07 — Agency “current” discrepancy","The §31 agency page retains a definition removed by the July 15, 2025 rule; the 2026 CFR reflects removal.","The stale definition was not used. This is concrete evidence that a current-page label is not a complete currency audit."],["F08 — Regulation Z discrepancies","Posted scope comment is narrower than amended closed-end text; partial-payment comment has the paragraph-reference mismatch described above.","Operative clauses and final amendment used; inconsistencies disclosed."],["F09 — Historical effective-date discrepancy","S020’s front matter and §VI state different effective dates for the 2010 former rule while agreeing on mandatory compliance.","No historical transaction result is based on choosing one silently."],["F10 — Search discoveries not treated as law","Searches surfaced proposed and unrelated material, including the 2024 proposed servicing changes at https://www.federalregister.gov/documents/2024/07/24/2024-15475/streamlining-mortgage-servicing-for-borrowers-experiencing-payment-difficulties-regulation-x. Its operative body was not used.","Discovery only; no proposed rule applied as current law."],["F11 — Guidance status","No CFPB circular, bulletin, or advisory supplied a substantive rule in this report.","The user’s withdrawn-guidance cross-check condition was not triggered. No withdrawal is equated with statutory repeal."],["F12 — Opinions and case records","No majority opinion was necessary or relied upon. Case references appearing inside a preamble were not treated as opinions read. No actual case record, docket, or status query occurred.","No holding, disposition, later-history, standing, or remedy claim is made."],["F13 — Read extent","Necessary clauses/comments were opened as body text; snippets and indexes served only discovery. Large final-rule and full-part PDFs were read only within reported bounds.","No claim of whole-document review or independent review."]]},{"headers":["Status category","Treatment in this component"],"index":13,"links":[],"row_links":[[],[],[],[],[],[],[],[],[]],"rows":[["Status category","Treatment in this component"],["Current retrieved text","House compilation text, agency operative provisions, and identified annual CFR editions, subject to their exact date and retrieval limits."],["Historical final rules","Used for adoption, implementation, and model history; former numbering or superseded wording is not applied as current operative text."],["Interim final rule","S021 is expressly identified as interim final, with its stated effective date; it is not mislabeled a proposal."],["Proposed/future material","No proposal or unverified future provision supplies an operative result. No comprehensive inventory of pending proposals is claimed."],["Removed/repealed material","The §31 COVID definition’s regulatory removal is identified. No inference of repeal of §2605 or §1641 follows."],["Withdrawn guidance","None used; no guidance-withdrawal conclusion needed or made."],["Stayed/vacated/other adverse status","No provision is labeled stayed or vacated without authority. Conversely, this report does not certify an exhaustive absence of such developments through the check date."],["Unknown","Exact unresolved retrieval, historical-date, image, currentness, and factual limits are listed above rather than converted into “no rule” findings."]]},{"headers":["Assignment question","Principal claims","Principal sources","Supporting deliverable"],"index":14,"links":[],"row_links":[[],[],[],[],[],[],[],[]],"rows":[["Assignment question","Principal claims","Principal sources","Supporting deliverable"],["1. Necessary coverage, triggers, actors, exclusions, and adjacent definitions","C001–C020; C038–C044; C058","S001–S005, S007–S008, S013–S014, S019","Scope findings; matrix; E01–E02, E07–E08, E12"],["2. Servicing notices, timing, delivery, content, current models","C018–C031; C062","S001, S006, S008–S012, S017","Notice findings; model read bounds; worksheet"],["3. Transition payments, receipt, grace period, partial/nonreceived payment","C032–C037; C066","S001, S007, S009, S011, S017","Proof-category table; E04–E06, E13"],["4. Ownership acquisition, timing, content, exceptions, multiple transfers, agents, proof limits","C038–C061","S003, S013–S020","Ownership findings; E02–E03, E09–E12"],["5. Comparison, blank audit, at least eight hypothetical branches, no invented dates","C001, C021–C023, C032, C045, C061, C066","Underlying sources above","Matrix; 35 blank audit items; E01–E14"],["Source/version/access standards","C062–C065","S001–S024","Source register; read/failure log; status classification"],["Owner limits and parent holds","C061, C066","Assignment boundaries","Self-check and holds below"]]},{"headers":["Check","Result"],"index":15,"links":[],"row_links":[[],[],[],[],[],[],[],[],[],[],[],[],[],[],[]],"rows":[["Check","Result"],["Servicing transfer separated from debt ownership and property succession","Yes—separate definitions, duties, and hypothetical branches"],["Statutory wording separated from regulations, interpretations, and historical preambles","Yes—including the due-date wording and product-scope differences"],["Necessary operative exceptions and relevant comments read","Yes within reported text bounds; the complete currentness audit remains limited"],["Mailing of notice separated from receipt of payment","Yes"],["No universal 60-day holiday, blanket reporting immunity, or presumed cure","Yes"],["Model content separated from enumerated mandatory content","Yes"],["Complete MS-2 parsed text distinguished from image inspection","Yes; pixel verification remains unresolved"],["Ownership notice separated from assignment/security/standing proof","Yes"],["Multiple transfers, joint acquisitions, partial interests, agents, and contact-only changes addressed","Yes"],["At least eight hypothetical branches; no identifying entries","Yes—fourteen qualitative branches"],["No actual-calendar deadline or amount invented","Yes"],["No actual records, filings, contacts, publication, or individualized decision","Yes"],["No unreviewed prior-report foundation or subagent review","Yes"],["Source failures and textual inconsistencies disclosed","Yes"]]}],"claims":[{"claim_id":"R006-P1-C001","area_numbers":[6],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"R006-P1-C001","Area and precise claim":"Servicing rights, ownership of the debt, and ownership of property securing the debt are separate subjects in these provisions.","Trigger, conditions, and exceptions":"A single transaction may affect more than one, but one label does not establish the others.","Source pinpoint":"S001 §2605(i); S007 §31; S014 §39(a)(1).","Status / limit":"R/S; separation and proof limitation are I."},"coordinator_verification_status":"scoped_conditional_framework_reviewed_historical_or_currentness_bounds_retained","coordinator_review":"[internal evidence reference]"},{"claim_id":"R006-P1-C002","area_numbers":[6],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"R006-P1-C002","Area and precise claim":"RESPA’s statutory federally related mortgage-loan definition requires qualifying residential collateral and a specified federal/lender nexus.","Trigger, conditions, and exceptions":"First or subordinate lien on principally one-to-four-family residential real property; non-temporary financing; federally insured/regulated lender, federal assistance, intended specified secondary-market sale, or qualifying creditor making/investing more than $1 million per year in residential real-estate loans. State agencies are excluded from that last creditor branch.","Source pinpoint":"S002 §2602(1)(A)–(B).","Status / limit":"S; collateral alone is insufficient."},"coordinator_verification_status":"scoped_conditional_framework_reviewed_historical_or_currentness_bounds_retained","coordinator_review":"[internal evidence reference]"},{"claim_id":"R006-P1-C003","area_numbers":[6],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"R006-P1-C003","Area and precise claim":"Regulation X adds necessary detail concerning residential structures, manufactured homes, dealer/broker originations, reverse mortgages, and financed land/installment contracts.","Trigger, conditions, and exceptions":"Apply each §2 definition branch. The security must be in a defined “State,” including DC, Puerto Rico, and US territories/possessions. A manufactured-home or contract-for-deed label alone is insufficient.","Source pinpoint":"S004 §2, “Federally related mortgage loan” (1)–(3), “State.”","Status / limit":"R; no foreign-law or actual-product determination."},"coordinator_verification_status":"scoped_conditional_framework_reviewed_historical_or_currentness_bounds_retained","coordinator_review":"[internal evidence reference]"},{"claim_id":"R006-P1-C004","area_numbers":[6],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"R006-P1-C004","Area and precise claim":"Primarily business, commercial, or agricultural credit is excluded under the relevant RESPA provisions; credit to government/agencies/instrumentalities is statutorily excluded.","Trigger, conditions, and exceptions":"Purpose is assessed under the specified Regulation Z interpretation, not simply a document’s “business loan” label.","Source pinpoint":"S002 §2606(a)–(b); S005 §5(b)(2); S013 §3(a).","Status / limit":"S/R/O; no actual purpose classification."},"coordinator_verification_status":"scoped_conditional_framework_reviewed_historical_or_currentness_bounds_retained","coordinator_review":"[internal evidence reference]"},{"claim_id":"R006-P1-C005","area_numbers":[6],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"R006-P1-C005","Area and precise claim":"The temporary-financing exemption has operative qualifications.","Trigger, conditions, and exceptions":"It does not cover qualifying construction used as, convertible by the same lender to, or committed to permanent financing, or financing transfer to the first user. Qualifying construction of two years or more, except a bona fide builder loan, is covered. Bridge/swing financing is excluded as specified.","Source pinpoint":"S005 §5(b)(3).","Status / limit":"R; no universal “construction loan” result."},"coordinator_verification_status":"scoped_conditional_framework_reviewed_historical_or_currentness_bounds_retained","coordinator_review":"[internal evidence reference]"},{"claim_id":"R006-P1-C006","area_numbers":[6],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"R006-P1-C006","Area and precise claim":"Other §5(b) exclusions are conditional.","Trigger, conditions, and exceptions":"Vacant/unimproved land: exception where proceeds will fund the specified structure/home within two years. Assumption: distinguish no lender approval right from required and obtained approval. Conversion: original-instrument-consistent changes without a required new note.","Source pinpoint":"S005 §5(b)(4)–(6).","Status / limit":"R; transaction facts remain unknown."},"coordinator_verification_status":"scoped_conditional_framework_reviewed_historical_or_currentness_bounds_retained","coordinator_review":"[internal evidence reference]"},{"claim_id":"R006-P1-C007","area_numbers":[6],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"R006-P1-C007","Area and precise claim":"The secondary-market exemption expressly preserves §2605 and Subpart C.","Trigger, conditions, and exceptions":"Table-funded transactions and the specified initial dealer-loan transactions are not secondary-market transactions. Section 5(d)’s partial exemptions include §33(a), not a blanket exemption from §33(b)–(c).","Source pinpoint":"S005 §5(b)(7), (d).","Status / limit":"R; an ownership sale does not automatically escape servicing provisions."},"coordinator_verification_status":"scoped_conditional_framework_reviewed_historical_or_currentness_bounds_retained","coordinator_review":"[internal evidence reference]"},{"claim_id":"R006-P1-C008","area_numbers":[6],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"R006-P1-C008","Area and precise claim":"Subpart C expressly excludes open-end home-equity plans; §33 has no general principal-residence restriction.","Trigger, conditions, and exceptions":"The principal-residence restriction in §30(c)(2) concerns §§39–41. Small-servicer, reverse-mortgage, and qualified-lender exemptions in §30(b) concern §§38–41, subject to their terms—not a blanket §33 exemption.","Source pinpoint":"S007 §§30(b)–(c), 31 “Mortgage loan.”","Status / limit":"R/O. The HELOC exclusion is regulatory wording, not an express phrase in §2605(b)–(d)."},"coordinator_verification_status":"scoped_conditional_framework_reviewed_historical_or_currentness_bounds_retained","coordinator_review":"[internal evidence reference]"},{"claim_id":"R006-P1-C009","area_numbers":[6],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"R006-P1-C009","Area and precise claim":"A servicer is the person responsible for servicing, including a maker or holder that also services.","Trigger, conditions, and exceptions":"Servicing concerns receiving scheduled payments and making required onward payments; Regulation X includes payments to the borrower for reverse mortgages.","Source pinpoint":"S001 §2605(i)(2)–(3); S004 “Servicer,” “Servicing.”","Status / limit":"S/R; being an owner alone does not establish servicing."},"coordinator_verification_status":"scoped_conditional_framework_reviewed_historical_or_currentness_bounds_retained","coordinator_review":"[internal evidence reference]"},{"claim_id":"R006-P1-C010","area_numbers":[6],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"R006-P1-C010","Area and precise claim":"Section 2605(i)(2) has named federal-actor exclusions.","Trigger, conditions, and exceptions":"FDIC/RTC specified asset or receivership/conservatorship functions; and the named Ginnie Mae/Fannie Mae/Freddie Mac/RTC/FDIC actors where the specified predecessor servicing termination, bankruptcy, or FDIC/RTC proceeding occurred.","Source pinpoint":"S001 §2605(i)(2)(A)–(B).","Status / limit":"S; statutory RTC wording is reported, not silently modernized."},"coordinator_verification_status":"scoped_conditional_framework_reviewed_historical_or_currentness_bounds_retained","coordinator_review":"[internal evidence reference]"},{"claim_id":"R006-P1-C011","area_numbers":[6],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"R006-P1-C011","Area and precise claim":"Regulation X’s servicer exclusions must be read separately from the statutory list.","Trigger, conditions, and exceptions":"Specified FDIC functions; specified NCUA functions; and the named FNMA, Freddie Mac, FDIC, HUD—including GNMA/FHA—NCUA, Farm Service Agency, and VA actors in the enumerated cause-termination, bankruptcy, FDIC, or NCUA circumstances.","Source pinpoint":"S004 “Servicer” (1)–(3).","Status / limit":"R; government involvement or insurance alone does not establish an exclusion."},"coordinator_verification_status":"scoped_conditional_framework_reviewed_historical_or_currentness_bounds_retained","coordinator_review":"[internal evidence reference]"},{"claim_id":"R006-P1-C012","area_numbers":[6],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"R006-P1-C012","Area and precise claim":"Master servicer, subservicer, transferor, and transferee are distinct functional definitions.","Trigger, conditions, and exceptions":"Master owns the servicing right; subservicer performs for the master without owning it. Transferor transfers, and transferee obtains, the right to perform servicing under an agreement/understanding. Specified table-funding brokers/dealers can be transferors.","Source pinpoint":"S007 §31 definitions.","Status / limit":"R; no blanket “mere subservicing” exemption follows."},"coordinator_verification_status":"scoped_conditional_framework_reviewed_historical_or_currentness_bounds_retained","coordinator_review":"[internal evidence reference]"},{"claim_id":"R006-P1-C013","area_numbers":[6],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"R006-P1-C013","Area and precise claim":"The servicing effective date generally is the date payment is first due to the transferee pursuant to the servicing transfer.","Trigger, conditions, and exceptions":"For a HECM/reverse mortgage, §2 uses the transfer date agreed by the two servicers.","Source pinpoint":"S001 §2605(i)(1); S004 “Effective date of transfer.”","Status / limit":"S/R; not automatically sale, recording, letter, or receipt date."},"coordinator_verification_status":"scoped_conditional_framework_reviewed_historical_or_currentness_bounds_retained","coordinator_review":"[internal evidence reference]"},{"claim_id":"R006-P1-C014","area_numbers":[6],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"R006-P1-C014","Area and precise claim":"A successor in interest here receives a qualifying interest in the secured property, not the creditor’s debt.","Trigger, conditions, and exceptions":"Five categories: specified death/survivorship transfers; relative after borrower’s death; spouse/children ownership; specified marital dissolution/separation/property settlement; qualifying inter vivos trust without occupancy-right transfer. Confirmation requires identity and property-interest confirmation by the servicer.","Source pinpoint":"S007 §31; Successor comments 1–2.","Status / limit":"R/O; trust beneficiaries, rather than the trust itself, are addressed by the trust comment."},"coordinator_verification_status":"scoped_conditional_framework_reviewed_historical_or_currentness_bounds_retained","coordinator_review":"[internal evidence reference]"},{"claim_id":"R006-P1-C015","area_numbers":[6],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"R006-P1-C015","Area and precise claim":"A confirmed successor is treated as a borrower for the relevant Regulation X provisions without mandatory assumption.","Trigger, conditions, and exceptions":"That treatment does not determine contractual liability. Applicable obligations to the original borrower continue.","Source pinpoint":"S007 §30(d), comments 1–3.","Status / limit":"R/O; property succession is not debt acquisition by a covered person."},"coordinator_verification_status":"scoped_conditional_framework_reviewed_historical_or_currentness_bounds_retained","coordinator_review":"[internal evidence reference]"},{"claim_id":"R006-P1-C016","area_numbers":[6],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"R006-P1-C016","Area and precise claim":"Section 32(c)’s optional notice-and-acknowledgment procedure can condition specified communications to a confirmed successor who is not liable.","Trigger, conditions, and exceptions":"Requires a compliant notice and separate acknowledgment limited to the permitted subjects: confirmation; nonliability/conditional security explanation; notice entitlement; request/understanding; no return deadline; and explanation of retained error, information, and payoff-request rights with addresses.","Source pinpoint":"S008 §32(c)(1)(i)–(v).","Status / limit":"R; merely saying “no assumption” does not establish this exception."},"coordinator_verification_status":"scoped_conditional_framework_reviewed_historical_or_currentness_bounds_retained","coordinator_review":"[internal evidence reference]"},{"claim_id":"R006-P1-C017","area_numbers":[6],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"R006-P1-C017","Area and precise claim":"The successor communication limitations are narrow.","Trigger, conditions, and exceptions":"With a compliant procedure, specified disclosures may be withheld until assumption or acknowledgment; revocation has its stated effect. Copies must be available on oral/written request. Providing the same specific disclosure to another borrower can satisfy §32(c)(4).","Source pinpoint":"S008 §32(c)(2)–(4), comments 32(c)(2)-1–2.","Status / limit":"R/O; no blanket disappearance of successor or original-borrower rights."},"coordinator_verification_status":"scoped_conditional_framework_reviewed_historical_or_currentness_bounds_retained","coordinator_review":"[internal evidence reference]"},{"claim_id":"R006-P1-C018","area_numbers":[6],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"R006-P1-C018","Area and precise claim":"Ordinarily, both transferor and transferee owe a servicing-transfer notice.","Trigger, conditions, and exceptions":"A qualifying mortgage servicing assignment, sale, or transfer; apply coverage, actor, transfer, and successor exceptions first.","Source pinpoint":"S001 §2605(b)(1), (c)(1); S009 §33(b)(1).","Status / limit":"S/R; a change of debt owner is not required."},"coordinator_verification_status":"scoped_conditional_framework_reviewed_historical_or_currentness_bounds_retained","coordinator_review":"[internal evidence reference]"},{"claim_id":"R006-P1-C019","area_numbers":[6],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"R006-P1-C019","Area and precise claim":"Three specified transfer categories are excluded only when all four listed payment features remain unchanged.","Trigger, conditions, and exceptions":"Affiliate transfer; merger/acquisition of servicers or subservicers; or master-servicer transfer without changing subservicer. Required unchanged features: payee, payment-delivery address, account number, and payment amount.","Source pinpoint":"S009 §33(b)(2)(i)(A)–(C).","Status / limit":"R; unchanged features alone do not create an additional unlisted category."},"coordinator_verification_status":"scoped_conditional_framework_reviewed_historical_or_currentness_bounds_retained","coordinator_review":"[internal evidence reference]"},{"claim_id":"R006-P1-C020","area_numbers":[6],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"R006-P1-C020","Area and precise claim":"FHA has a specific notice exception when a National Housing Act-insured mortgage is assigned to FHA.","Trigger, conditions, and exceptions":"Applies to FHA’s stated duty; it is not a blanket exemption for every participant or every FHA-insured loan.","Source pinpoint":"S009 §33(b)(2)(ii).","Status / limit":"R; distinguish from the servicer-definition exclusions."},"coordinator_verification_status":"scoped_conditional_framework_reviewed_historical_or_currentness_bounds_retained","coordinator_review":"[internal evidence reference]"},{"claim_id":"R006-P1-C021","area_numbers":[6],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"R006-P1-C021","Area and precise claim":"Ordinary clocks are transferor ≥15 days before; transferee ≤15 days after; combined servicing notice ≥15 days before.","Trigger, conditions, and exceptions":"Calendar days under §31. The transferee deadline does not require waiting until after transfer. No weekend/holiday exclusion or extra mailing days is stated for these clocks.","Source pinpoint":"S001 §2605(b)(2)(A), (c)(2)(A); S007 “Day”; S009 §33(b)(3)(i).","Status / limit":"S/R; no actual calendar calculation made."},"coordinator_verification_status":"scoped_conditional_framework_reviewed_historical_or_currentness_bounds_retained","coordinator_review":"[internal evidence reference]"},{"claim_id":"R006-P1-C022","area_numbers":[6],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"R006-P1-C022","Area and precise claim":"The specified distress events permit notice no later than 30 days after the effective date.","Trigger, conditions, and exceptions":"Transfer must be preceded by servicing-contract termination for cause, commencement of servicer bankruptcy, specified FDIC proceedings, or specified NCUA proceedings. Statutory text separately names FDIC/RTC.","Source pinpoint":"S001 §2605(b)(2)(B), (c)(2)(B); S009 §33(b)(3)(ii).","Status / limit":"S/R; anticipated distress or ordinary inconvenience is not the stated trigger."},"coordinator_verification_status":"scoped_conditional_framework_reviewed_historical_or_currentness_bounds_retained","coordinator_review":"[internal evidence reference]"},{"claim_id":"R006-P1-C023","area_numbers":[6],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"R006-P1-C023","Area and precise claim":"Compliant transfer notices at settlement satisfy the regulation’s timing requirement.","Trigger, conditions, and exceptions":"Separate or combined transferor/transferee notices under §33(b)(3)(iii). Statutory closing language refers to the loan maker providing the specified written notice.","Source pinpoint":"S001 §2605(b)(2)(C), (c)(2)(C); S009 §33(b)(3)(iii).","Status / limit":"S/R; no automatic settlement exception under §1026.39."},"coordinator_verification_status":"scoped_conditional_framework_reviewed_historical_or_currentness_bounds_retained","coordinator_review":"[internal evidence reference]"},{"claim_id":"R006-P1-C024","area_numbers":[6],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"R006-P1-C024","Area and precise claim":"Regulation X disclosures generally must be clear, conspicuous, written, and retainable.","Trigger, conditions, and exceptions":"Electronic delivery is conditioned on E-Sign consumer consent and other applicable requirements. Foreign-language disclosures must be available in English on request. Combination is permitted unless prohibited by applicable law or specified regulatory agreement.","Source pinpoint":"S008 §32(a)–(b).","Status / limit":"R; an email’s existence does not establish compliant electronic delivery."},"coordinator_verification_status":"scoped_conditional_framework_reviewed_historical_or_currentness_bounds_retained","coordinator_review":"[internal evidence reference]"},{"claim_id":"R006-P1-C025","area_numbers":[6],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"R006-P1-C025","Area and precise claim":"For mailing under Regulation X, placing correctly addressed material in the mail can satisfy the mailing requirement whether or not received.","Trigger, conditions, and exceptions":"Use §11 and transfer comment 33(b)(3)-1: appropriate borrower address(es), including a qualifying notified change. A notice’s printed date alone does not prove dispatch.","Source pinpoint":"S006 §11; S009 comment 33(b)(3)-1.","Status / limit":"R/O; the last sentence is I. Actual payment receipt uses a different test."},"coordinator_verification_status":"scoped_conditional_framework_reviewed_historical_or_currentness_bounds_retained","coordinator_review":"[internal evidence reference]"},{"claim_id":"R006-P1-C026","area_numbers":[6],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"R006-P1-C026","Area and precise claim":"The servicing notice must disclose the effective date and usable contacts for both servicers.","Trigger, conditions, and exceptions":"For each servicer, §33(b)(4)(ii)–(iii) specifies employee/department name, address, and toll-free or collect-call telephone number for transfer inquiries. Statutory subparagraphs separately identify the transferee and contacts.","Source pinpoint":"S001 §2605(b)(3)(A)–(D), (c)(3); S009 §33(b)(4)(i)–(iii).","Status / limit":"S/R; ownership identification is a separate regime."},"coordinator_verification_status":"scoped_conditional_framework_reviewed_historical_or_currentness_bounds_retained","coordinator_review":"[internal evidence reference]"},{"claim_id":"R006-P1-C027","area_numbers":[6],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"R006-P1-C027","Area and precise claim":"Remaining required servicing content concerns acceptance dates, optional insurance, and unchanged nonservicing terms.","Trigger, conditions, and exceptions":"Old stop/new start acceptance dates must be the same or consecutive days; disclose optional-insurance effects and necessary preservation actions; state transfer does not affect terms other than directly servicing-related terms.","Source pinpoint":"S001 §2605(b)(3)(E)–(G); S009 §33(b)(4)(iv)–(vi).","Status / limit":"S/R; statutory wording concerns security instruments; regulation refers to mortgage-loan terms."},"coordinator_verification_status":"scoped_conditional_framework_reviewed_historical_or_currentness_bounds_retained","coordinator_review":"[internal evidence reference]"},{"claim_id":"R006-P1-C028","area_numbers":[6],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"R006-P1-C028","Area and precise claim":"Current MS-2 also includes a payment-address instruction and a 60-day protection paragraph.","Trigger, conditions, and exceptions":"Those model passages must be distinguished from §33(b)(4)’s enumerated content. The final-rule explanation retained them without making every model sentence an independent enumerated requirement.","Source pinpoint":"S010 MS-2; S017 pp.10732, 10839; S011 pp.752–753.","Status / limit":"R/H; omission is not automatically classified solely by model comparison. Operative “beginning” controls over the model’s “following” wording."},"coordinator_verification_status":"scoped_conditional_framework_reviewed_historical_or_currentness_bounds_retained","coordinator_review":"[internal evidence reference]"},{"claim_id":"R006-P1-C029","area_numbers":[6],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"R006-P1-C029","Area and precise claim":"MS-2 is optional; appropriate use has the stated disclosure-compliance protection.","Trigger, conditions, and exceptions":"Required information still must be supplied. Permissible changes must preserve substance, clarity, and meaningful sequence; inapplicable content may be removed. Successor wording may avoid implying personal liability.","Source pinpoint":"S010/S011 Appendix MS comments 1–2, including 2(iv)(A)–(C).","Status / limit":"O; no actual notice compliance or broader immunity found."},"coordinator_verification_status":"scoped_conditional_framework_reviewed_historical_or_currentness_bounds_retained","coordinator_review":"[internal evidence reference]"},{"claim_id":"R006-P1-C030","area_numbers":[6],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"R006-P1-C030","Area and precise claim":"The application-stage servicing disclosure is separate from an actual transfer notice.","Trigger, conditions, and exceptions":"Current §33(a) applies to reverse-mortgage applications; its three-day period excludes legal public holidays, Saturdays, and Sundays; timely denial is an exception. Section 2’s general business-day definition is not substituted for this express exclusion.","Source pinpoint":"S009 §33(a), comments 1–3; S007 §30(c)(1); S004 “Business day.”","Status / limit":"R/O; MS-1 and MS-2 serve different events."},"coordinator_verification_status":"scoped_conditional_framework_reviewed_historical_or_currentness_bounds_retained","coordinator_review":"[internal evidence reference]"},{"claim_id":"R006-P1-C031","area_numbers":[6],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"R006-P1-C031","Area and precise claim":"The preemption provisions concern the specified notice requirements; they do not resolve all state-law issues.","Trigger, conditions, and exceptions":"§2605(h), §33(d), and §5(c) must be read together. Section 33(d) preserves specified notices to insurance companies or taxing authorities.","Source pinpoint":"S001 §2605(h); S005 §5(c); S009 §33(d).","Status / limit":"S/R/O; state title, assignment, contract, and other law remain held."},"coordinator_verification_status":"scoped_conditional_framework_reviewed_historical_or_currentness_bounds_retained","coordinator_review":"[internal evidence reference]"},{"claim_id":"R006-P1-C032","area_numbers":[6],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"R006-P1-C032","Area and precise claim":"The protection concerns a payment received by the transferor during the 60-day period beginning on the servicing effective date.","Trigger, conditions, and exceptions":"Statute says receipt before the applicable due date; regulation says on or before, including a grace period allowed by the loan instruments. Apply the regulation’s actual wording rather than silently paraphrasing the two texts as identical.","Source pinpoint":"S001 §2605(d); S009 §33(c)(1); S011 §33.","Status / limit":"S/R; begins with the transfer event, not notice receipt."},"coordinator_verification_status":"scoped_conditional_framework_reviewed_historical_or_currentness_bounds_retained","coordinator_review":"[internal evidence reference]"},{"claim_id":"R006-P1-C033","area_numbers":[6],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"R006-P1-C033","Area and precise claim":"A qualifying payment may not be treated as late for any purpose; late fees are included.","Trigger, conditions, and exceptions":"This does not establish an account-wide credit-reporting freeze, protection for unrelated unpaid installments, or general immunity. Comment 33(c)(1)-2 says compliance with §1024.39 during the period is not itself prohibited late treatment.","Source pinpoint":"S009 comments 33(c)(1)-1–2; S001 §2605(d), distinguished from (e)(3).","Status / limit":"S/R/O; broader reporting/remedies questions held."},"coordinator_verification_status":"scoped_conditional_framework_reviewed_historical_or_currentness_bounds_retained","coordinator_review":"[internal evidence reference]"},{"claim_id":"R006-P1-C034","area_numbers":[6],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"R006-P1-C034","Area and precise claim":"Beginning on the effective date, the old servicer must promptly forward an incorrectly received payment or return it and notify the payor of the proper recipient.","Trigger, conditions, and exceptions":"Forwarding must be to the transferee for account application. Return must be to the person who paid, with the recipient notification. The clause states no numerical “promptly” deadline, no express 60-day end, and no specified written form for that notification.","Source pinpoint":"S009 §33(c)(2)(i)–(ii); S017 p.10733.","Status / limit":"R/H; do not invent a forward-only duty or fixed number of days."},"coordinator_verification_status":"scoped_conditional_framework_reviewed_historical_or_currentness_bounds_retained","coordinator_review":"[internal evidence reference]"},{"claim_id":"R006-P1-C035","area_numbers":[6],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"R006-P1-C035","Area and precise claim":"Inclusion of an instrument-authorized grace period in this protection does not itself amend the contractual due date, principal, rate, or amount.","Trigger, conditions, and exceptions":"Official delinquency commentary distinguishes a due-and-unpaid installment from a later late-fee assessment date. The transfer provision controls the specified treatment of qualifying misdirected payments.","Source pinpoint":"S007 Delinquency comment 1; S009 §33(b)(4)(vi), (c)(1).","Status / limit":"O/R plus I; actual contract and accrual remain held."},"coordinator_verification_status":"scoped_conditional_framework_reviewed_historical_or_currentness_bounds_retained","coordinator_review":"[internal evidence reference]"},{"claim_id":"R006-P1-C036","area_numbers":[6],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"R006-P1-C036","Area and precise claim":"Sending, scheduling, or postmarking a payment is not the same factual proposition as old-servicer receipt.","Trigger, conditions, and exceptions":"Relevant predicates include actual recipient and receipt time, transfer effective date, applicable due/grace terms, and which payment the receipt concerns.","Source pinpoint":"S009 §33(c)(1)–(2).","Status / limit":"I from the receipt wording; unknown receipt stays U."},"coordinator_verification_status":"scoped_conditional_framework_reviewed_historical_or_currentness_bounds_retained","coordinator_review":"[internal evidence reference]"},{"claim_id":"R006-P1-C037","area_numbers":[6],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"R006-P1-C037","Area and precise claim":"A partial payment must not be treated as proof that a full installment was satisfied.","Trigger, conditions, and exceptions":"Do not categorically erase the misdirection protection merely because a payment was partial; separately determine what was received and what remained unpaid. The payment-tolerance comment applies if the servicer elects the specified treatment.","Source pinpoint":"S007 §31 “Delinquency,” comments 1–3; S009 §33(c); S014 §39(d)(5).","Status / limit":"I/O; allocation, sufficient-payment treatment, and actual shortfall remain U/held."},"coordinator_verification_status":"scoped_conditional_framework_reviewed_historical_or_currentness_bounds_retained","coordinator_review":"[internal evidence reference]"},{"claim_id":"R006-P1-C038","area_numbers":[6],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"R006-P1-C038","Area and precise claim":"Section 1641(g) requires the new owner/assignee to give a written ownership-transfer notice within its stated 30-day period.","Trigger, conditions, and exceptions":"Statutory mortgage definition: consumer credit secured by the consumer’s principal dwelling. Content: new creditor identity/contact, transfer date, authorized contact, recording location, and relevant additional information.","Source pinpoint":"S003 §1641(g)(1)–(2).","Status / limit":"S; separate from servicing notice."},"coordinator_verification_status":"scoped_conditional_framework_reviewed_historical_or_currentness_bounds_retained","coordinator_review":"[internal evidence reference]"},{"claim_id":"R006-P1-C039","area_numbers":[6],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"R006-P1-C039","Area and precise claim":"Current §39’s closed-end coverage is broader than the statute’s stated principal-dwelling definition.","Trigger, conditions, and exceptions":"Open-end: principal dwelling. Closed-end: dwelling or real property. Posted comment 39(a)(2)-1 still describes principal-dwelling coverage; amended text, comment 39(d)-2, and the final amendment establish the broader closed-end wording.","Source pinpoint":"S014 §39(a)(2), comments 39(a)(2)-1 and 39(d)-2; S018 p.80130; S016.","Status / limit":"R/O/H; discrepancy disclosed, not silently reconciled by narrowing the rule."},"coordinator_verification_status":"scoped_conditional_framework_reviewed_historical_or_currentness_bounds_retained","coordinator_review":"[internal evidence reference]"},{"claim_id":"R006-P1-C040","area_numbers":[6],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"R006-P1-C040","Area and precise claim":"Consumer, dwelling, and person are distinct definitions.","Trigger, conditions, and exceptions":"Consumer credit is primarily personal/family/household. A dwelling can be a qualifying residential structure without real-property status. A covered owner can be an organization; an organizational purchaser does not thereby turn the borrower’s loan into organizational credit.","Source pinpoint":"S013 §2(a)(11), (12), (19), (22), comments.","Status / limit":"R/O; last sentence I."},"coordinator_verification_status":"scoped_conditional_framework_reviewed_historical_or_currentness_bounds_retained","coordinator_review":"[internal evidence reference]"},{"claim_id":"R006-P1-C041","area_numbers":[6],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"R006-P1-C041","Area and precise claim":"Business-purpose and organizational-credit exclusions require the correct borrower/transaction analysis.","Trigger, conditions, and exceptions":"Section 3(a) applies; necessary trust interpretations prevent treating every trust transaction as automatically excluded.","Source pinpoint":"S013 §3(a)(1)–(2), relevant comments; §2(a)(11) comments.","Status / limit":"R/O; no actual consumer/business or trust determination."},"coordinator_verification_status":"scoped_conditional_framework_reviewed_historical_or_currentness_bounds_retained","coordinator_review":"[internal evidence reference]"},{"claim_id":"R006-P1-C042","area_numbers":[6],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"R006-P1-C042","Area and precise claim":"A §39 covered person acquires legal title to an existing mortgage debt and acquires more than one mortgage loan in any twelve-month period.","Trigger, conditions, and exceptions":"Purchase, assignment, or other transfer can qualify; the person need not satisfy Regulation Z’s separate “creditor” definition. Partial and joint legal-title acquisitions can qualify.","Source pinpoint":"S014 §39(a)(1), comments 1–2.","Status / limit":"R/O; acquisition frequency and actual legal title are not presumed."},"coordinator_verification_status":"scoped_conditional_framework_reviewed_historical_or_currentness_bounds_retained","coordinator_review":"[internal evidence reference]"},{"claim_id":"R006-P1-C043","area_numbers":[6],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"R006-P1-C043","Area and precise claim":"Beneficial interest, a security interest, or credit risk without legal title does not satisfy the legal-title trigger.","Trigger, conditions, and exceptions":"Administrative-convenience assignment to a servicer is also excluded as specified.","Source pinpoint":"S003 §1641(f)(1)–(3); S014 §39(a)(1), comment 3.","Status / limit":"S/R/O; securitization or servicing labels alone do not decide the issue."},"coordinator_verification_status":"scoped_conditional_framework_reviewed_historical_or_currentness_bounds_retained","coordinator_review":"[internal evidence reference]"},{"claim_id":"R006-P1-C044","area_numbers":[6],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"R006-P1-C044","Area and precise claim":"Affiliation does not itself excuse an ownership disclosure.","Trigger, conditions, and exceptions":"Acquisition by a separate legal entity, including through a qualifying merger, acquisition, or reorganization, is addressed by the ownership rule, subject to its other conditions.","Source pinpoint":"S014 comments 39(a)(1)-2(iii), -4.","Status / limit":"O; do not import the Regulation X affiliate exception."},"coordinator_verification_status":"scoped_conditional_framework_reviewed_historical_or_currentness_bounds_retained","coordinator_review":"[internal evidence reference]"},{"claim_id":"R006-P1-C045","area_numbers":[6],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"R006-P1-C045","Area and precise claim":"The owner must mail or deliver by the 30th calendar day following its defined transfer date.","Trigger, conditions, and exceptions":"The covered person may use acquisition recognized in its books or transfer recognized in the transferor’s books. No business-day exclusion, holiday extension, or extra presumed receipt period is stated here.","Source pinpoint":"S014 §39(b), (b)(2); S016.","Status / limit":"R; notice date or recording date is not freely substituted."},"coordinator_verification_status":"scoped_conditional_framework_reviewed_historical_or_currentness_bounds_retained","coordinator_review":"[internal evidence reference]"},{"claim_id":"R006-P1-C046","area_numbers":[6],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"R006-P1-C046","Area and precise claim":"Ownership disclosures must be clear, conspicuous, written, and retainable; electronic provision is E-Sign-conditioned.","Trigger, conditions, and exceptions":"With multiple liable consumers, delivery to any primarily liable consumer is permitted by §39(b)(3). Combining with servicing notices is allowed only if applicable requirements are met.","Source pinpoint":"S014 §39(b)(1), (3), comment 39(b)(1)-1.","Status / limit":"R/O; do not import this recipient rule into §33."},"coordinator_verification_status":"scoped_conditional_framework_reviewed_historical_or_currentness_bounds_retained","coordinator_review":"[internal evidence reference]"},{"claim_id":"R006-P1-C047","area_numbers":[6],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"R006-P1-C047","Area and precise claim":"Disposition of all acquired interest by the 30th calendar day can exempt that intermediate acquirer.","Trigger, conditions, and exceptions":"Retention of a partial interest on that day prevents reliance on this particular exception. The next acquirer requires its own analysis.","Source pinpoint":"S014 §39(c)(1), comments 1–2.","Status / limit":"R/O; no chain-wide exemption."},"coordinator_verification_status":"scoped_conditional_framework_reviewed_historical_or_currentness_bounds_retained","coordinator_review":"[internal evidence reference]"},{"claim_id":"R006-P1-C048","area_numbers":[6],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"R006-P1-C048","Area and precise claim":"A qualifying repurchase agreement can excuse disclosure while its specified arrangement applies.","Trigger, conditions, and exceptions":"The transferor must be obligated to repurchase. If repurchase does not occur, the covered person must disclose within 30 days after recognizing acquisition on its books; the interpretation also addresses intermediaries.","Source pinpoint":"S014 §39(c)(2), comment 1.","Status / limit":"R/O; not every temporary holding or warehouse arrangement qualifies."},"coordinator_verification_status":"scoped_conditional_framework_reviewed_historical_or_currentness_bounds_retained","coordinator_review":"[internal evidence reference]"},{"claim_id":"R006-P1-C049","area_numbers":[6],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"R006-P1-C049","Area and precise claim":"The partial-interest exception requires both a partial acquisition and no specified authorized-contact change.","Trigger, conditions, and exceptions":"The party authorized to receive rescission notice and resolve payment issues must remain unchanged as a result of the transfer. Same servicer alone does not establish the exception; acquisition of the remaining interest is separately addressed by the comment.","Source pinpoint":"S014 §39(c)(3), comments 1–2.","Status / limit":"R/O; no general “same servicer” exemption."},"coordinator_verification_status":"scoped_conditional_framework_reviewed_historical_or_currentness_bounds_retained","coordinator_review":"[internal evidence reference]"},{"claim_id":"R006-P1-C050","area_numbers":[6],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"R006-P1-C050","Area and precise claim":"For sequential acquisitions, one disclosure for multiple covered persons is optional if each person’s requirements are met.","Trigger, conditions, and exceptions":"Each retains its compliance duty. A subsequent transfer date may be estimated only under the comment’s unknown/reasonably-available, good-faith diligence standard.","Source pinpoint":"S014 §39(b)(4), comments 1–3.","Status / limit":"R/O; no invented actual dates."},"coordinator_verification_status":"scoped_conditional_framework_reviewed_historical_or_currentness_bounds_retained","coordinator_review":"[internal evidence reference]"},{"claim_id":"R006-P1-C051","area_numbers":[6],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"R006-P1-C051","Area and precise claim":"Joint acquisition requires a single disclosure for the joint covered persons.","Trigger, conditions, and exceptions":"Where completion dates differ, the comment uses the earliest acquisition’s clock. Separate, unrelated partial acquisitions are different: each duty remains, although a compliant combined disclosure is possible.","Source pinpoint":"S014 §39(b)(5), comments 1–4; 39(a)(1)-2(ii).","Status / limit":"R/O; “multiple owners” does not by itself establish joint acquisition."},"coordinator_verification_status":"scoped_conditional_framework_reviewed_historical_or_currentness_bounds_retained","coordinator_review":"[internal evidence reference]"},{"claim_id":"R006-P1-C052","area_numbers":[6],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"R006-P1-C052","Area and precise claim":"The notice must identify the transferred loan and provide the covered owner’s name, address, telephone number, and transfer date.","Trigger, conditions, and exceptions":"Loan identification must be sufficient under the comment; no actual or invented identifying value is entered here. Servicer contact alone is not ordinarily a substitute for owner identification.","Source pinpoint":"S014 §39(d), (d)(1)–(2), comments 39(d)-1 and 39(d)(1)-1.","Status / limit":"R/O."},"coordinator_verification_status":"scoped_conditional_framework_reviewed_historical_or_currentness_bounds_retained","coordinator_review":"[internal evidence reference]"},{"claim_id":"R006-P1-C053","area_numbers":[6],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"R006-P1-C053","Area and precise claim":"A combined notice ordinarily identifies each covered person; a narrow authorized-owner exception can permit identification of only one.","Trigger, conditions, and exceptions":"The identified party must itself be a covered person authorized for both specified rescission and payment functions.","Source pinpoint":"S014 §39(d)(1)(i)–(ii), corresponding comments.","Status / limit":"R/O; identifying any servicing agent is not equivalent."},"coordinator_verification_status":"scoped_conditional_framework_reviewed_historical_or_currentness_bounds_retained","coordinator_review":"[internal evidence reference]"},{"claim_id":"R006-P1-C054","area_numbers":[6],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"R006-P1-C054","Area and precise claim":"The authorized-contact disclosure concerns receiving rescission notices and resolving payment issues.","Trigger, conditions, and exceptions":"Owner contact can suffice if usable for those purposes. If multiple agents are listed, their differing authority must be explained. No new agent need be appointed; email/website are optional.","Source pinpoint":"S014 §39(d)(3), comments 1–2.","Status / limit":"R/O; this content requirement does not create an otherwise absent rescission right."},"coordinator_verification_status":"scoped_conditional_framework_reviewed_historical_or_currentness_bounds_retained","coordinator_review":"[internal evidence reference]"},{"claim_id":"R006-P1-C055","area_numbers":[6],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"R006-P1-C055","Area and precise claim":"The recording disclosure permits the stated alternatives.","Trigger, conditions, and exceptions":"Disclose where ownership transfer is or may be recorded, or truthfully that it has not been recorded when notice is provided. The comment does not require an exact street address.","Source pinpoint":"S014 §39(d)(4), comment 1.","Status / limit":"R/O; neither recording nor validity is established by the notice’s assertion."},"coordinator_verification_status":"scoped_conditional_framework_reviewed_historical_or_currentness_bounds_retained","coordinator_review":"[internal evidence reference]"},{"claim_id":"R006-P1-C056","area_numbers":[6],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"R006-P1-C056","Area and precise claim":"Applicable closed-end notices must disclose the partial-payment policy under the specified heading.","Trigger, conditions, and exceptions":"Excludes reverse mortgages from this additional content, not automatically the entire ownership rule. State the applicable accept/apply, accept/hold-until-complete, or reject policy; include that a later lender may have a different policy.","Source pinpoint":"S014 §39(d) introductory text, (d)(5)(i)–(iv); S018 p.80130.","Status / limit":"R; a policy disclosure is not an adjudication of lawful payment application."},"coordinator_verification_status":"scoped_conditional_framework_reviewed_historical_or_currentness_bounds_retained","coordinator_review":"[internal evidence reference]"},{"claim_id":"R006-P1-C057","area_numbers":[6],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"R006-P1-C057","Area and precise claim":"Old application dates do not create a perpetual exclusion from §39(d)(5).","Trigger, conditions, and exceptions":"The official implementation commentary addresses October 3, 2015 transition treatment and conditions occurring on or after October 1, 2018, regardless of application date.","Source pinpoint":"S015 comment 1(d)(5)-1, especially post-consummation provisions.","Status / limit":"O; no individual deadline calculated."},"coordinator_verification_status":"scoped_conditional_framework_reviewed_historical_or_currentness_bounds_retained","coordinator_review":"[internal evidence reference]"},{"claim_id":"R006-P1-C058","area_numbers":[6],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"R006-P1-C058","Area and precise claim":"Regulation Z includes confirmed-successor treatment and a specified notice/acknowledgment limitation.","Trigger, conditions, and exceptions":"Apply §2(a)(11), (27) and §39(f)’s actual wording, including the compliant Regulation X notice, nonliability, assumption, acknowledgment, and revocation conditions.","Source pinpoint":"S013 relevant successor definitions/comments; S014 §39(f); S019 instruction 22.","Status / limit":"R/O; not a general owner exemption or determination of personal liability."},"coordinator_verification_status":"scoped_conditional_framework_reviewed_historical_or_currentness_bounds_retained","coordinator_review":"[internal evidence reference]"},{"claim_id":"R006-P1-C059","area_numbers":[6],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"R006-P1-C059","Area and precise claim":"Transmission on another covered person’s behalf is contemplated; substantive responsibility is not erased.","Trigger, conditions, and exceptions":"Current multiple-person provisions expressly allocate duties; the 2013 explanation contemplates owner/servicer arrangements for required disclosure. A sender’s letterhead alone proves neither ownership nor authority nor compliance.","Source pinpoint":"S014 §39(b)(4)–(5), duty comments; S018 pp.80059–80060.","Status / limit":"R/O; broader agent-delivery conclusion is bounded I. Actual agency is U."},"coordinator_verification_status":"scoped_conditional_framework_reviewed_historical_or_currentness_bounds_retained","coordinator_review":"[internal evidence reference]"},{"claim_id":"R006-P1-C060","area_numbers":[6],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"R006-P1-C060","Area and precise claim":"A contact change alone, without qualifying acquisition, is not the §39 ownership-transfer trigger.","Trigger, conditions, and exceptions":"Conversely, a qualifying partial transfer plus change of the specified authorized party can defeat §39(c)(3)’s exception. Other contact-update duties are outside this component.","Source pinpoint":"S014 §39(a), (c)(3), (d)(3), (e).","Status / limit":"I from the stated trigger; no general exemption from other law."},"coordinator_verification_status":"scoped_conditional_framework_reviewed_historical_or_currentness_bounds_retained","coordinator_review":"[internal evidence reference]"},{"claim_id":"R006-P1-C061","area_numbers":[6],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"R006-P1-C061","Area and precise claim":"These disclosure provisions do not make a notice conclusive proof of assignment, title, security rights, balance, or standing.","Trigger, conditions, and exceptions":"Likewise, absence or defect of notice does not itself establish invalid assignment, debt cancellation, or a remedy. Distinct substantive and evidentiary law would be needed.","Source pinpoint":"S001 §2605(b)–(d); S003 §1641(g); S014 §39(a), (d).","Status / limit":"Expressly bounded I; all actual legal-status and litigation questions held."},"coordinator_verification_status":"scoped_conditional_framework_reviewed_historical_or_currentness_bounds_retained","coordinator_review":"[internal evidence reference]"},{"claim_id":"R006-P1-C062","area_numbers":[6],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"R006-P1-C062","Precise claim":"Current MS-2 retains the short payment-transition protection paragraph. Historical complaint-resolution/QWR language and proposals discussed in the 2013 preamble are not imported as current required transfer-notice content.","Source pinpoint":"S010–S012; S017 pp.10730–10733, 10839.","Status / limit":"H/R/O; current text controls; no historical full-form reconstruction claimed."},"coordinator_verification_status":"scoped_conditional_framework_reviewed_historical_or_currentness_bounds_retained","coordinator_review":"[internal evidence reference]"},{"claim_id":"R006-P1-C063","area_numbers":[6],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"R006-P1-C063","Precise claim":"Agency “current” labels and House compilation dates do not establish a complete through-today legal audit. Direct eCFR and 2026 annual §39 body gaps remain.","Source pinpoint":"S001–S003, S016, S022–S024.","Status / limit":"U as to exhaustive currency; substantive retrieved text identified precisely."},"coordinator_verification_status":"historical_currentness_limit_reviewed_not_fully_replicated","coordinator_review":"[internal evidence reference]"},{"claim_id":"R006-P1-C064","area_numbers":[6],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"R006-P1-C064","Precise claim":"Relevant implementation dates are separate from access dates: §1641(g)’s May 20, 2009 statutory event; 2013 servicing rule’s January 10, 2014 effective date; successor provisions’ April 19, 2018 effective date; partial-payment transition in C057.","Source pinpoint":"S003, S015, S017, S019–S020.","Status / limit":"S/H/O. The 2010 former-rule effective-date discrepancy is not resolved or used to decide a historical transaction."},"coordinator_verification_status":"historical_currentness_limit_reviewed_not_fully_replicated","coordinator_review":"[internal evidence reference]"},{"claim_id":"R006-P1-C065","area_numbers":[6],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"R006-P1-C065","Precise claim":"The posted §31 page’s COVID definition is stale relative to the 2025 removal and 2026 annual CFR. The relevant day, servicing, mortgage-loan, and successor definitions were separately checked.","Source pinpoint":"S007; S011 §§30–31; S021 instruction 2.","Status / limit":"R/H; this finding does not reopen COVID servicing or foreclosure law."},"coordinator_verification_status":"scoped_conditional_framework_reviewed_historical_or_currentness_bounds_retained","coordinator_review":"[internal evidence reference]"},{"claim_id":"R006-P1-C066","area_numbers":[6],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"R006-P1-C066","Precise claim":"No actual transfer date, receipt date, contractual payment deadline, amount, or individual compliance result has been established.","Source pinpoint":"Assignment limits; C013, C021–C023, C032, C045.","Status / limit":"U by design. All periods remain event-triggered; no actual-calendar arithmetic performed."},"coordinator_verification_status":"scoped_conditional_framework_reviewed_historical_or_currentness_bounds_retained","coordinator_review":"[internal evidence reference]"}],"sources":[{"source_id":"R006-P1-S001","urls":["https://uscode.house.gov/us/usc/119-124/t12/s2605/","https://www.govinfo.gov/content/pkg/USCODE-2024-title12/html/USCODE-2024-title12-chap27-sec2605.htm","https://uscode.house.gov/us/usc/119-124/t12/s2605/?utm_source=chatgpt.com","https://www.govinfo.gov/content/pkg/USCODE-2024-title12/html/USCODE-2024-title12-chap27-sec2605.htm?utm_source=chatgpt.com"],"researcher_record":{"Source ID":"R006-P1-S001","Issuer/title and complete literal HTTPS URL(s)":"House Office of Law Revision Counsel, 12 USC §2605, Servicing of mortgage loans and administration of escrow accounts.\nhttps://uscode.house.gov/us/usc/119-124/t12/s2605/\nEarlier GPO compilation:\nhttps://www.govinfo.gov/content/pkg/USCODE-2024-title12/html/USCODE-2024-title12-chap27-sec2605.htm","Exact read bounds / pinpoint":"Complete necessary (b), (c), (d), (h), (i), (j); (a) for the application/transfer distinction. Adjacent (e)(3) read only to distinguish its separate credit-reporting clock. Other displayed provisions were not analyzed as assigned subjects.","Version and effective predicate; read status and currentness limit":"House: laws in effect through PL119-124, October 15, 2026. GPO: 2024 edition, initially read, then superseded for current statutory wording by the House read. Fresh; reused. Statutory notice and payment triggers are in the cited subsections. No full post-compilation session-law audit. \nuscode.house.gov\n+2"},"coordinator_verification_status":"fresh_selected_partial_group","coordinator_review":"[internal evidence reference]"},{"source_id":"R006-P1-S002","urls":["https://uscode.house.gov/us/usc/119-124/t12/s2602/","https://uscode.house.gov/us/usc/119-124/t12/s2606/","https://www.govinfo.gov/content/pkg/USCODE-2024-title12/html/USCODE-2024-title12-chap27-sec2602.htm","https://www.govinfo.gov/link/uscode/12/2606","https://uscode.house.gov/us/usc/119-124/t12/s2602/?utm_source=chatgpt.com","https://uscode.house.gov/us/usc/119-124/t12/s2606/?utm_source=chatgpt.com","https://www.govinfo.gov/content/pkg/USCODE-2024-title12/html/USCODE-2024-title12-chap27-sec2602.htm?utm_source=chatgpt.com","https://www.govinfo.gov/link/uscode/12/2606?utm_source=chatgpt.com"],"researcher_record":{"Source ID":"R006-P1-S002","Issuer/title and complete literal HTTPS URL(s)":"House OLRC, 12 USC §§2602 and 2606, definitions and exempted transactions.\nhttps://uscode.house.gov/us/usc/119-124/t12/s2602/\nhttps://uscode.house.gov/us/usc/119-124/t12/s2606/\nEarlier reads:\nhttps://www.govinfo.gov/content/pkg/USCODE-2024-title12/html/USCODE-2024-title12-chap27-sec2602.htm\nhttps://www.govinfo.gov/link/uscode/12/2606","Exact read bounds / pinpoint":"§2602 (1), (5) and relevant editorial notes; complete §2606 (a)–(b). The §2606 GovInfo PDF was printed p.1452, index 0, parsed text only.","Version and effective predicate; read status and currentness limit":"House: through PL119-124, October 15, 2026. Earlier §2602 HTML: 2024. Edition of the isolated §2606 link PDF was not independently established; the later House read supplies the reported compilation version. Fresh; reused. \nuscode.house.gov\n+2"},"coordinator_verification_status":"fresh_selected_body","coordinator_review":"[internal evidence reference]"},{"source_id":"R006-P1-S003","urls":["https://uscode.house.gov/us/usc/119-134/t15/s1641/","https://www.govinfo.gov/content/pkg/USCODE-2024-title15/html/USCODE-2024-title15-chap41-subchapI-partB-sec1641.htm","https://uscode.house.gov/us/usc/119-134/t15/s1641/?utm_source=chatgpt.com","https://www.govinfo.gov/content/pkg/USCODE-2024-title15/html/USCODE-2024-title15-chap41-subchapI-partB-sec1641.htm?utm_source=chatgpt.com"],"researcher_record":{"Source ID":"R006-P1-S003","Issuer/title and complete literal HTTPS URL(s)":"House OLRC, 15 USC §1641, Liability of assignees.\nhttps://uscode.house.gov/us/usc/119-134/t15/s1641/\nEarlier GPO compilation:\nhttps://www.govinfo.gov/content/pkg/USCODE-2024-title15/html/USCODE-2024-title15-chap41-subchapI-partB-sec1641.htm","Exact read bounds / pinpoint":"Complete necessary (f) and (g); source credit and amendment notes. Other liability provisions displayed on the page are outside this component.","Version and effective predicate; read status and currentness limit":"House: through PL119-134, October 20, 2026. Subsection (g) added by PL111-22, May 20, 2009. Earlier GPO 2024 text freshly read, then checked against House. No remedies analysis or full later-law audit. \nuscode.house.gov"},"coordinator_verification_status":"fresh_partial_with_specific_failure","coordinator_review":"[internal evidence reference]"},{"source_id":"R006-P1-S004","urls":["https://www.consumerfinance.gov/rules-policy/regulations/1024/2/","https://www.consumerfinance.gov/rules-policy/regulations/1024/2/?utm_source=chatgpt.com"],"researcher_record":{"Source ID":"R006-P1-S004","Issuer/title and complete literal HTTPS URL(s)":"CFPB, Regulation X §1024.2, Definitions.\nhttps://www.consumerfinance.gov/rules-policy/regulations/1024/2/","Exact read bounds / pinpoint":"Complete necessary definitions of business day; effective date of transfer; federally related mortgage loan; servicer; servicing; State; table funding, and relevant lender/dealer/broker definitions.","Version and effective predicate; read status and currentness limit":"Agency page labeled current; part-version limitation in S022. Fresh selected-body read. Necessary federal nexus, property, actor, and reverse-mortgage conditions read in full; no general underwriting analysis. \nConsumer Financial Protection Bureau\n+1"},"coordinator_verification_status":"fresh_selected_body","coordinator_review":"[internal evidence reference]"},{"source_id":"R006-P1-S005","urls":["https://www.consumerfinance.gov/rules-policy/regulations/1024/5/","https://www.consumerfinance.gov/rules-policy/regulations/1024/5/?utm_source=chatgpt.com"],"researcher_record":{"Source ID":"R006-P1-S005","Issuer/title and complete literal HTTPS URL(s)":"CFPB, §1024.5, Coverage of RESPA.\nhttps://www.consumerfinance.gov/rules-policy/regulations/1024/5/","Exact read bounds / pinpoint":"Complete (a)–(d) and relevant embedded official interpretations, particularly (b)(2)–(7), (c)(1), (c)(4), (d).","Version and effective predicate; read status and currentness limit":"Agency-current label, subject to S022. Fresh full operative section read. Exceptions are section-specific; secondary-market and partial exemptions cannot be generalized. \nConsumer Financial Protection Bureau"},"coordinator_verification_status":"fresh_selected_body","coordinator_review":"[internal evidence reference]"},{"source_id":"R006-P1-S006","urls":["https://www.consumerfinance.gov/rules-policy/regulations/1024/11/","https://www.consumerfinance.gov/rules-policy/regulations/1024/11/?utm_source=chatgpt.com"],"researcher_record":{"Source ID":"R006-P1-S006","Issuer/title and complete literal HTTPS URL(s)":"CFPB, §1024.11, Mailing.\nhttps://www.consumerfinance.gov/rules-policy/regulations/1024/11/","Exact read bounds / pinpoint":"Entire operative mailing paragraph.","Version and effective predicate; read status and currentness limit":"Agency-current label. Fresh full-body read. Applies by its terms to mailing provisions of “this part”; used together with transfer-specific address interpretation, not as a payment-receipt rule. \nConsumer Financial Protection Bureau"},"coordinator_verification_status":"fresh_selected_body","coordinator_review":"[internal evidence reference]"},{"source_id":"R006-P1-S007","urls":["https://www.consumerfinance.gov/rules-policy/regulations/1024/30/","https://www.consumerfinance.gov/rules-policy/regulations/1024/31/","https://www.consumerfinance.gov/rules-policy/regulations/1024/interp-31/","https://www.consumerfinance.gov/rules-policy/regulations/1024/30/?utm_source=chatgpt.com","https://www.consumerfinance.gov/rules-policy/regulations/1024/31/?utm_source=chatgpt.com","https://www.consumerfinance.gov/rules-policy/regulations/1024/interp-31/?utm_source=chatgpt.com"],"researcher_record":{"Source ID":"R006-P1-S007","Issuer/title and complete literal HTTPS URL(s)":"CFPB, §§1024.30–.31, scope, definitions, and official interpretations.\nhttps://www.consumerfinance.gov/rules-policy/regulations/1024/30/\nhttps://www.consumerfinance.gov/rules-policy/regulations/1024/31/\nhttps://www.consumerfinance.gov/rules-policy/regulations/1024/interp-31/","Exact read bounds / pinpoint":"§30 (a)–(d) and comments; §31 necessary definitions, including day, mortgage loan, master/subservicer, transferor/transferee, successor and confirmed successor; official Delinquency comments 1–4 and Successor comments 1–2.","Version and effective predicate; read status and currentness limit":"Fresh; reused. The agency §31 page still displays the later-removed COVID definition. That stale item is not used; S011 and S021 address the discrepancy. Successor amendments relevant here took effect April 19, 2018. \nConsumer Financial Protection Bureau\n+3"},"coordinator_verification_status":"fresh_selected_body","coordinator_review":"[internal evidence reference]"},{"source_id":"R006-P1-S008","urls":["https://www.consumerfinance.gov/rules-policy/regulations/1024/32/","https://www.consumerfinance.gov/rules-policy/regulations/1024/32/?utm_source=chatgpt.com"],"researcher_record":{"Source ID":"R006-P1-S008","Issuer/title and complete literal HTTPS URL(s)":"CFPB, §1024.32, General disclosure requirements.\nhttps://www.consumerfinance.gov/rules-policy/regulations/1024/32/","Exact read bounds / pinpoint":"Complete (a)–(c) and embedded interpretations, including 32(c)(1)-1; 32(c)(2)-1 and -2.","Version and effective predicate; read status and currentness limit":"Fresh full necessary body/comments. Successor procedure effective April 19, 2018, S019. No inference that a generic acknowledgment establishes actual personal liability or valid security rights. \nConsumer Financial Protection Bureau\n+2"},"coordinator_verification_status":"fresh_selected_body","coordinator_review":"[internal evidence reference]"},{"source_id":"R006-P1-S009","urls":["https://www.consumerfinance.gov/rules-policy/regulations/1024/33/","https://www.consumerfinance.gov/rules-policy/regulations/1024/interp-33/","https://www.consumerfinance.gov/rules-policy/regulations/1024/33/?utm_source=chatgpt.com","https://www.consumerfinance.gov/rules-policy/regulations/1024/interp-33/?utm_source=chatgpt.com"],"researcher_record":{"Source ID":"R006-P1-S009","Issuer/title and complete literal HTTPS URL(s)":"CFPB, §1024.33, Mortgage servicing transfers, and Supplement I.\nhttps://www.consumerfinance.gov/rules-policy/regulations/1024/33/\nhttps://www.consumerfinance.gov/rules-policy/regulations/1024/interp-33/","Exact read bounds / pinpoint":"Complete (a)–(d); comments 33(a)-1 through -3; 33(b)(3)-1; 33(c)(1)-1 and -2.","Version and effective predicate; read status and currentness limit":"Fresh complete operative section and necessary comments. Current posting checked against 2026 annual CFR §33. Core 2013 servicing rule effective January 10, 2014; later amendment/history separately identified below. \nConsumer Financial Protection Bureau\n+2"},"coordinator_verification_status":"fresh_selected_body","coordinator_review":"[internal evidence reference]"},{"source_id":"R006-P1-S010","urls":["https://www.consumerfinance.gov/rules-policy/regulations/1024/ms/","https://www.consumerfinance.gov/rules-policy/regulations/1024/ms2/","https://www.consumerfinance.gov/rules-policy/regulations/1024/interp-ms/","https://www.consumerfinance.gov/rules-policy/regulations/1024/ms/?utm_source=chatgpt.com","https://www.consumerfinance.gov/rules-policy/regulations/1024/ms2/?utm_source=chatgpt.com","https://www.consumerfinance.gov/rules-policy/regulations/1024/interp-ms/?utm_source=chatgpt.com"],"researcher_record":{"Source ID":"R006-P1-S010","Issuer/title and complete literal HTTPS URL(s)":"CFPB, Appendix MS, MS-2, and official model instructions.\nhttps://www.consumerfinance.gov/rules-policy/regulations/1024/ms/\nhttps://www.consumerfinance.gov/rules-policy/regulations/1024/ms2/\nhttps://www.consumerfinance.gov/rules-policy/regulations/1024/interp-ms/","Exact read bounds / pinpoint":"Entire posted MS-2 notice text. Appendix MS general instructions 1–2, with complete continuation/examples verified in annual CFR rather than assuming the website excerpt was complete.","Version and effective predicate; read status and currentness limit":"Fresh. Current generic model, not an actual notice. Model use is optional and conditional. No H-25 form was used or claimed to have been inspected. \nConsumer Financial Protection Bureau\n+2"},"coordinator_verification_status":"fresh_selected_body","coordinator_review":"[internal evidence reference]"},{"source_id":"R006-P1-S011","urls":["https://www.govinfo.gov/content/pkg/CFR-2026-title12-vol8/pdf/CFR-2026-title12-vol8-sec1024-33.pdf","https://www.govinfo.gov/content/pkg/CFR-2026-title12-vol8/pdf/CFR-2026-title12-vol8-part1024.pdf","https://www.govinfo.gov/content/pkg/CFR-2026-title12-vol8/pdf/CFR-2026-title12-vol8-sec1024-33.pdf?utm_source=chatgpt.com","https://www.govinfo.gov/content/pkg/CFR-2026-title12-vol8/pdf/CFR-2026-title12-vol8-part1024.pdf?utm_source=chatgpt.com"],"researcher_record":{"Source ID":"R006-P1-S011","Issuer/title and complete literal HTTPS URL(s)":"OFR/GPO, 2026 annual CFR, Regulation X.\nhttps://www.govinfo.gov/content/pkg/CFR-2026-title12-vol8/pdf/CFR-2026-title12-vol8-sec1024-33.pdf\nhttps://www.govinfo.gov/content/pkg/CFR-2026-title12-vol8/pdf/CFR-2026-title12-vol8-part1024.pdf","Exact read bounds / pinpoint":"§33 granule: printed pp.704–706, indexes 0–2, complete §33. Full-part PDF: selected §§30–32 text pp.702–704, indexes 28–30; relevant comments pp.756–758, indexes 82–84; complete MS-2 pp.752–753, indexes 78–79; complete general MS instructions p.782, index 108.","Version and effective predicate; read status and currentness limit":"January 1, 2026 edition; 110-page full-part file not read in full. Parsed-text read. Screenshot requests for indexes 78–79 returned display markers without inspectable image blocks through this tool: no pixel-level verification claimed. Fresh; same-edition reproductions, not independent corroboration. \ngovinfo.gov\n+3"},"coordinator_verification_status":"fresh_selected_partial_group","coordinator_review":"[internal evidence reference]"},{"source_id":"R006-P1-S012","urls":["https://www.govinfo.gov/content/pkg/CFR-2025-title12-vol8/pdf/CFR-2025-title12-vol8-sec1024-33.pdf","https://www.govinfo.gov/content/pkg/CFR-2025-title12-vol8/pdf/CFR-2025-title12-vol8-part1024.pdf","https://www.govinfo.gov/content/pkg/CFR-2025-title12-vol8/pdf/CFR-2025-title12-vol8-part1024-appMS.pdf","https://www.govinfo.gov/content/pkg/CFR-2025-title12-vol8/pdf/CFR-2025-title12-vol8-sec1024-33.pdf?utm_source=chatgpt.com","https://www.govinfo.gov/content/pkg/CFR-2025-title12-vol8/pdf/CFR-2025-title12-vol8-part1024.pdf?utm_source=chatgpt.com","https://www.govinfo.gov/content/pkg/CFR-2025-title12-vol8/pdf/CFR-2025-title12-vol8-part1024-appMS.pdf?utm_source=chatgpt.com"],"researcher_record":{"Source ID":"R006-P1-S012","Issuer/title and complete literal HTTPS URL(s)":"OFR/GPO, 2025 annual CFR, Regulation X, earlier verification copies.\nhttps://www.govinfo.gov/content/pkg/CFR-2025-title12-vol8/pdf/CFR-2025-title12-vol8-sec1024-33.pdf\nhttps://www.govinfo.gov/content/pkg/CFR-2025-title12-vol8/pdf/CFR-2025-title12-vol8-part1024.pdf\nhttps://www.govinfo.gov/content/pkg/CFR-2025-title12-vol8/pdf/CFR-2025-title12-vol8-part1024-appMS.pdf","Exact read bounds / pinpoint":"Selected §33; complete MS-2 parsed across pp.754–755, full-part indexes 80–81; general MS instructions p.785, index 111. Isolated appendix granule contains p.754 only, index 0—it is not the complete MS-2.","Version and effective predicate; read status and currentness limit":"January 1, 2025 edition, supplanted for annual-edition verification by S011. Screenshot retrieval included a timeout/recovery; no additional pixel-read claim is necessary or made. The 113-page full part was not fully read. \ngovinfo.gov\n+2"},"coordinator_verification_status":"unreopened_historical_parallel","coordinator_review":"[internal evidence reference]"},{"source_id":"R006-P1-S013","urls":["https://www.consumerfinance.gov/rules-policy/regulations/1026/2/","https://www.consumerfinance.gov/rules-policy/regulations/1026/3/","https://www.consumerfinance.gov/rules-policy/regulations/1026/2/?utm_source=chatgpt.com","https://www.consumerfinance.gov/rules-policy/regulations/1026/3/?utm_source=chatgpt.com"],"researcher_record":{"Source ID":"R006-P1-S013","Issuer/title and complete literal HTTPS URL(s)":"CFPB, Regulation Z §§1026.2–.3, necessary definitions and exemptions.\nhttps://www.consumerfinance.gov/rules-policy/regulations/1026/2/\nhttps://www.consumerfinance.gov/rules-policy/regulations/1026/3/","Exact read bounds / pinpoint":"§2 (a)(6), (10)–(12), (19), (22), (27) and relevant consumer, dwelling, person, trust, and successor comments; §3 (a)(1)–(2) and corresponding interpretations.","Version and effective predicate; read status and currentness limit":"Fresh selected-body read. Consumer-purpose and organizational-credit boundaries examined only as necessary for §39; no comprehensive origination, underwriting, or general Regulation Z gateway rerun. \nConsumer Financial Protection Bureau\n+3"},"coordinator_verification_status":"fresh_selected_body","coordinator_review":"[internal evidence reference]"},{"source_id":"R006-P1-S014","urls":["https://www.consumerfinance.gov/rules-policy/regulations/1026/39/","https://www.consumerfinance.gov/rules-policy/regulations/1026/interp-39/","https://www.consumerfinance.gov/rules-policy/regulations/1026/39/?utm_source=chatgpt.com","https://www.consumerfinance.gov/rules-policy/regulations/1026/interp-39/?utm_source=chatgpt.com"],"researcher_record":{"Source ID":"R006-P1-S014","Issuer/title and complete literal HTTPS URL(s)":"CFPB, §1026.39, Mortgage transfer disclosures, and Supplement I.\nhttps://www.consumerfinance.gov/rules-policy/regulations/1026/39/\nhttps://www.consumerfinance.gov/rules-policy/regulations/1026/interp-39/","Exact read bounds / pinpoint":"Complete (a)–(f) and relevant embedded official comments: 39(a)(1)-1–4; (a)(2)-1; (b)(1)-1; (b)(4)-1–3; (b)(5)-1–4; (c)(1)-1–2; (c)(2)-1; (c)(3)-1–2; (d)-1–2; (d)(1)-1; (d)(1)(i)-1; (d)(1)(ii)-1; (d)(3)-1–2; (d)(4)-1; (d)(5)-1; (e)-1.","Version and effective predicate; read status and currentness limit":"Fresh complete operative body/comments through the integrated page; standalone interpretation page used as associated source, not separate corroboration. Agency-current label subject to S022. Two textual inconsistencies are expressly recorded below. \nConsumer Financial Protection Bureau\n+3"},"coordinator_verification_status":"fresh_selected_body","coordinator_review":"[internal evidence reference]"},{"source_id":"R006-P1-S015","urls":["https://www.consumerfinance.gov/rules-policy/regulations/1026/1/","https://www.consumerfinance.gov/rules-policy/regulations/1026/1/?utm_source=chatgpt.com"],"researcher_record":{"Source ID":"R006-P1-S015","Issuer/title and complete literal HTTPS URL(s)":"CFPB, §1026.1, necessary implementation provisions and comments.\nhttps://www.consumerfinance.gov/rules-policy/regulations/1026/1/","Exact read bounds / pinpoint":"(c)(5); necessary (d)(5) material and comment 1(d)(5)-1, particularly the post-consummation treatment of §39(d)(5).","Version and effective predicate; read status and currentness limit":"Fresh selected read. Partial-payment disclosure implementation: October 3, 2015 transition; triggering conditions on or after October 1, 2018 apply regardless of application date. No general TRID analysis. \nConsumer Financial Protection Bureau"},"coordinator_verification_status":"fresh_selected_body","coordinator_review":"[internal evidence reference]"},{"source_id":"R006-P1-S016","urls":["https://www.govinfo.gov/content/pkg/CFR-2025-title12-vol9/pdf/CFR-2025-title12-vol9-sec1026-39.pdf","https://www.govinfo.gov/link/cfr/12/1026?link-type=pdf&sectionnum=39&year=mostrecent","https://www.govinfo.gov/content/pkg/CFR-2025-title12-vol9/pdf/CFR-2025-title12-vol9-sec1026-39.pdf?utm_source=chatgpt.com","https://www.govinfo.gov/link/cfr/12/1026?link-type=pdf&sectionnum=39&year=mostrecent&utm_source=chatgpt.com"],"researcher_record":{"Source ID":"R006-P1-S016","Issuer/title and complete literal HTTPS URL(s)":"OFR/GPO, 2025 annual CFR §1026.39.\nhttps://www.govinfo.gov/content/pkg/CFR-2025-title12-vol9/pdf/CFR-2025-title12-vol9-sec1026-39.pdf\nhttps://www.govinfo.gov/link/cfr/12/1026?link-type=pdf&sectionnum=39&year=mostrecent","Exact read bounds / pinpoint":"Complete §39, printed pp.139–141, indexes 0–2; neighboring §38/§40 fragments not treated as complete reads.","Version and effective predicate; read status and currentness limit":"Both routes returned the January 1, 2025 edition. Fresh parsed-text read; no image inspection. “Most recent” routing is not proof that a 2026 edition does not exist. \ngovinfo.gov\n+1"},"coordinator_verification_status":"fresh_selected_body","coordinator_review":"[internal evidence reference]"},{"source_id":"R006-P1-S017","urls":["https://www.govinfo.gov/content/pkg/FR-2013-02-14/pdf/2013-01248.pdf","https://www.govinfo.gov/content/pkg/FR-2013-02-14/pdf/2013-01248.pdf?utm_source=chatgpt.com"],"researcher_record":{"Source ID":"R006-P1-S017","Issuer/title and complete literal HTTPS URL(s)":"CFPB/OFR/GPO, Mortgage Servicing Rules Under RESPA (Regulation X), 2013 final rule.\nhttps://www.govinfo.gov/content/pkg/FR-2013-02-14/pdf/2013-01248.pdf","Exact read bounds / pinpoint":"Front effective-date text; selected §33 discussion printed pp.10727–10734, indexes 31–38; MS model discussion p.10839, index 143. Particularly payment-address treatment, complaint-resolution language, retained 60-day paragraph, and forwarding/return.","Version/effective predicate; status and limits":"Published February 14, 2013; relevant servicing rule effective January 10, 2014. Historical final-rule explanation, not a substitute for current codified text. The 204-page PDF was not fully read. No case cited inside its preamble was treated as a read opinion. \ngovinfo.gov\n+2"},"coordinator_verification_status":"fresh_selected_partial_group","coordinator_review":"[internal evidence reference]"},{"source_id":"R006-P1-S018","urls":["https://www.govinfo.gov/content/pkg/FR-2013-12-31/html/2013-28210.htm","https://www.govinfo.gov/content/pkg/FR-2013-12-31/html/2013-28210.htm?utm_source=chatgpt.com"],"researcher_record":{"Source ID":"R006-P1-S018","Issuer/title and complete literal HTTPS URL(s)":"CFPB/OFR/GPO, Integrated Mortgage Disclosures, 2013 final rule.\nhttps://www.govinfo.gov/content/pkg/FR-2013-12-31/html/2013-28210.htm","Exact read bounds / pinpoint":"Selected §39 discussion printed pp.80058–80060; amendment p.80130; comments p.80363. HTML printed-page markers, no PDF index.","Version/effective predicate; status and limits":"Final amendment expanded closed-end scope and added partial-payment disclosure. Original implementation dates were later modified; S015 supplies the relevant operative transition explanation. Selected body read, not the entire large rule. \ngovinfo.gov\n+2"},"coordinator_verification_status":"fresh_selected_partial_group","coordinator_review":"[internal evidence reference]"},{"source_id":"R006-P1-S019","urls":["https://www.govinfo.gov/content/pkg/FR-2016-10-19/pdf/2016-18901.pdf","https://www.govinfo.gov/content/pkg/FR-2016-10-19/pdf/2016-18901.pdf?utm_source=chatgpt.com"],"researcher_record":{"Source ID":"R006-P1-S019","Issuer/title and complete literal HTTPS URL(s)":"CFPB/OFR/GPO, 2016 Mortgage Servicing Amendments.\nhttps://www.govinfo.gov/content/pkg/FR-2016-10-19/pdf/2016-18901.pdf","Exact read bounds / pinpoint":"Front dates; selected successor amendments/discussion; §39(f) discussion p.72299, index 139; instruction 22 and §39(f) p.72388, index 228.","Version/effective predicate; status and limits":"Published October 19, 2016. Relevant successor provisions effective April 19, 2018, distinct from the rule’s general October 19, 2017 date. Selected read of a 242-page PDF. \ngovinfo.gov\n+1"},"coordinator_verification_status":"fresh_selected_partial_group","coordinator_review":"[internal evidence reference]"},{"source_id":"R006-P1-S020","urls":["https://www.govinfo.gov/content/pkg/FR-2010-09-24/pdf/2010-20664.pdf","https://www.govinfo.gov/content/pkg/FR-2010-09-24/pdf/2010-20664.pdf?utm_source=chatgpt.com"],"researcher_record":{"Source ID":"R006-P1-S020","Issuer/title and complete literal HTTPS URL(s)":"Federal Reserve/OFR/GPO, 2010 Regulation Z final rule and official staff commentary, former §226.39.\nhttps://www.govinfo.gov/content/pkg/FR-2010-09-24/pdf/2010-20664.pdf","Exact read bounds / pinpoint":"Front matter p.58489/index 0; selected ownership, multiple-transfer, exception and agent discussions pp.58491–58498/indexes 2–9; effective-date discussion p.58500/index 11; relevant former-rule/comment excerpts pp.58501–58504/indexes 12–15.","Version/effective predicate; status and limits":"Historical authority only. Front dates say January 1, 2011; §VI says effective October 25, 2010 with January 1, 2011 mandatory compliance. That internal historical-date discrepancy is preserved, not resolved. Both passages distinguish the statute’s May 20, 2009 enactment/effect. Current §1026.39 controls this report. \ngovinfo.gov\n+2"},"coordinator_verification_status":"fresh_route_failure_historical_text_unreplicated","coordinator_review":"[internal evidence reference]"},{"source_id":"R006-P1-S021","urls":["https://www.govinfo.gov/content/pkg/FR-2025-05-16/pdf/2025-08643.pdf","https://www.federalregister.gov/documents/2025/05/16/2025-08643/protections-for-borrowers-affected-by-the-covid-19-emergency-under-the-real-estate-settlement","https://www.govinfo.gov/content/pkg/FR-2025-05-16/pdf/2025-08643.pdf?utm_source=chatgpt.com","https://www.federalregister.gov/documents/2025/05/16/2025-08643/protections-for-borrowers-affected-by-the-covid-19-emergency-under-the-real-estate-settlement?utm_source=chatgpt.com"],"researcher_record":{"Source ID":"R006-P1-S021","Issuer/title and complete literal HTTPS URL(s)":"CFPB/OFR/GPO, 2025 COVID-era Regulation X rescission, interim final rule.\nhttps://www.govinfo.gov/content/pkg/FR-2025-05-16/pdf/2025-08643.pdf\nhttps://www.federalregister.gov/documents/2025/05/16/2025-08643/protections-for-borrowers-affected-by-the-covid-19-emergency-under-the-real-estate-settlement","Exact read bounds / pinpoint":"Effective-date text p.20791/index 0; instruction 2 removing the §31 COVID definition p.20792/index 1; amendment list and necessary cross-reference context.","Version/effective predicate; status and limits":"Interim final, effective July 15, 2025; not merely a proposal. Used to identify the agency-page currency discrepancy, not to reopen loss mitigation or foreclosure subjects. Official PDF checked; no claim to have read the complete five-page PDF. \ngovinfo.gov\n+1"},"coordinator_verification_status":"fresh_selected_body","coordinator_review":"[internal evidence reference]"},{"source_id":"R006-P1-S022","urls":["https://www.consumerfinance.gov/rules-policy/regulations/1024/versions/33/","https://www.consumerfinance.gov/rules-policy/regulations/1026/versions/39/","https://www.consumerfinance.gov/rules-policy/regulations/1024/versions/33/?utm_source=chatgpt.com","https://www.consumerfinance.gov/rules-policy/regulations/1026/versions/39/?utm_source=chatgpt.com"],"researcher_record":{"Source ID":"R006-P1-S022","Issuer/title and complete literal HTTPS URL(s)":"CFPB, regulation version lists.\nhttps://www.consumerfinance.gov/rules-policy/regulations/1024/versions/33/\nhttps://www.consumerfinance.gov/rules-policy/regulations/1026/versions/39/","Exact read bounds / pinpoint":"Version-list labels only.","Version/effective predicate; status and limits":"Retrieved lists identify April 19, 2023 for Regulation X and April 8, 2026 for Regulation Z as current versions. These are part-level website labels, not proof of each section’s amendment date or complete legal currency. Fresh metadata read. \nConsumer Financial Protection Bureau\n+1"},"coordinator_verification_status":"unreopened_metadata_only","coordinator_review":"[internal evidence reference]"},{"source_id":"R006-P1-S023","urls":["https://www.ecfr.gov/current/title-12/chapter-X/part-1024/section-1024.33","https://www.ecfr.gov/current/title-12/chapter-X/part-1026/section-1026.39","https://ecfr.federalregister.gov/current/title-12/chapter-X/part-1024/section-1024.33","https://ecfr.federalregister.gov/current/title-12/chapter-X/part-1026/section-1026.39"],"researcher_record":{"Source ID":"R006-P1-S023","Issuer/title and complete literal HTTPS URL(s)":"OFR eCFR section retrieval attempts.\nhttps://www.ecfr.gov/current/title-12/chapter-X/part-1024/section-1024.33\nhttps://www.ecfr.gov/current/title-12/chapter-X/part-1026/section-1026.39\nhttps://ecfr.federalregister.gov/current/title-12/chapter-X/part-1024/section-1024.33\nhttps://ecfr.federalregister.gov/current/title-12/chapter-X/part-1026/section-1026.39","Exact read bounds / pinpoint":"No operative body retrieved through these routes.","Version/effective predicate; status and limits":"Failure, not evidence of no rule. Annual CFR, agency text, and final rules supplied the substantive reads. No CAPTCHA or security workaround attempted."},"coordinator_verification_status":"fresh_route_failures","coordinator_review":"[internal evidence reference]"},{"source_id":"R006-P1-S024","urls":["https://www.govinfo.gov/content/pkg/CFR-2026-title12-vol9/pdf/CFR-2026-title12-vol9-sec1026-39.pdf"],"researcher_record":{"Source ID":"R006-P1-S024","Issuer/title and complete literal HTTPS URL(s)":"GovInfo attempted 2026 §1026.39 granule.\nhttps://www.govinfo.gov/content/pkg/CFR-2026-title12-vol9/pdf/CFR-2026-title12-vol9-sec1026-39.pdf","Exact read bounds / pinpoint":"No body retrieved.","Version/effective predicate; status and limits":"Failure. The alternative most-recent route returned S016’s 2025 edition. A fully verified 2026 annual §39 granule remains a precise source gap."},"coordinator_verification_status":"fresh_route_failure","coordinator_review":"[internal evidence reference]"}],"coverage":[{"topic":"§2605(b) transferor duty/content","researcher_record":{"Assigned subquestion / major branch":"§2605(b) transferor duty/content","Status":"A","Claim / example links":"C018, C021–C027","Exact missing authority or facts":"Actual coverage/event/notice facts absent","Next bounded permissible investigation":"None needed for the stated generic rule"},"raw_table_index":11,"coordinator_acceptance":"scoped_review_with_explicit_source_actualfact_and_parent_holds","coordinator_review":"[internal evidence reference]"},{"topic":"§2605(c) transferee duty/content","researcher_record":{"Assigned subquestion / major branch":"§2605(c) transferee duty/content","Status":"A","Claim / example links":"C018, C021–C027","Exact missing authority or facts":"Same","Next bounded permissible investigation":"Same"},"raw_table_index":11,"coordinator_acceptance":"scoped_review_with_explicit_source_actualfact_and_parent_holds","coordinator_review":"[internal evidence reference]"},{"topic":"§2605(d) payment protection","researcher_record":{"Assigned subquestion / major branch":"§2605(d) payment protection","Status":"A/U","Claim / example links":"C032–C037; E04–E06","Exact missing authority or facts":"Actual receipt, deadline, payment and treatment facts","Next bounded permissible investigation":"None without changing the no-record scope"},"raw_table_index":11,"coordinator_acceptance":"scoped_review_with_explicit_source_actualfact_and_parent_holds","coordinator_review":"[internal evidence reference]"},{"topic":"Statutory FRML definition","researcher_record":{"Assigned subquestion / major branch":"Statutory FRML definition","Status":"A","Claim / example links":"C002","Exact missing authority or facts":"Actual collateral/nexus","Next bounded permissible investigation":"Further generic definition authority only if a new product question is authorized"},"raw_table_index":11,"coordinator_acceptance":"scoped_review_with_explicit_source_actualfact_and_parent_holds","coordinator_review":"[internal evidence reference]"},{"topic":"§2606 purpose/government exclusions","researcher_record":{"Assigned subquestion / major branch":"§2606 purpose/government exclusions","Status":"A/U","Claim / example links":"C004","Exact missing authority or facts":"Actual purpose and recipient category","Next bounded permissible investigation":"No factual classification undertaken"},"raw_table_index":11,"coordinator_acceptance":"scoped_review_with_explicit_source_actualfact_and_parent_holds","coordinator_review":"[internal evidence reference]"},{"topic":"§1024.2 necessary definitions","researcher_record":{"Assigned subquestion / major branch":"§1024.2 necessary definitions","Status":"A","Claim / example links":"C003, C009–C013","Exact missing authority or facts":"Actual role and product facts","Next bounded permissible investigation":"None for stated branches"},"raw_table_index":11,"coordinator_acceptance":"scoped_review_with_explicit_source_actualfact_and_parent_holds","coordinator_review":"[internal evidence reference]"},{"topic":"Temporary/construction/bridge exclusions","researcher_record":{"Assigned subquestion / major branch":"Temporary/construction/bridge exclusions","Status":"A/U","Claim / example links":"C005","Exact missing authority or facts":"Financing structure, term, builder/permanent-finance conditions","Next bounded permissible investigation":"No actual-product investigation"},"raw_table_index":11,"coordinator_acceptance":"scoped_review_with_explicit_source_actualfact_and_parent_holds","coordinator_review":"[internal evidence reference]"},{"topic":"Vacant-land exclusion and exception","researcher_record":{"Assigned subquestion / major branch":"Vacant-land exclusion and exception","Status":"A/U","Claim / example links":"C006","Exact missing authority or facts":"Use of proceeds and construction/placement conditions","Next bounded permissible investigation":"Same"},"raw_table_index":11,"coordinator_acceptance":"scoped_review_with_explicit_source_actualfact_and_parent_holds","coordinator_review":"[internal evidence reference]"},{"topic":"Assumption and conversion exclusions","researcher_record":{"Assigned subquestion / major branch":"Assumption and conversion exclusions","Status":"A/U","Claim / example links":"C006","Exact missing authority or facts":"Approval right/permission; original terms/new note","Next bounded permissible investigation":"Contract work held"},"raw_table_index":11,"coordinator_acceptance":"scoped_review_with_explicit_source_actualfact_and_parent_holds","coordinator_review":"[internal evidence reference]"},{"topic":"Secondary-market carveback","researcher_record":{"Assigned subquestion / major branch":"Secondary-market carveback","Status":"A","Claim / example links":"C007","Exact missing authority or facts":"Actual transaction character","Next bounded permissible investigation":"None for the statutory/regulatory distinction"},"raw_table_index":11,"coordinator_acceptance":"scoped_review_with_explicit_source_actualfact_and_parent_holds","coordinator_review":"[internal evidence reference]"},{"topic":"Partial exemptions under §5(d)","researcher_record":{"Assigned subquestion / major branch":"Partial exemptions under §5(d)","Status":"A","Claim / example links":"C007","Exact missing authority or facts":"Whether a specific transaction meets them","Next bounded permissible investigation":"No general TRID gateway rerun"},"raw_table_index":11,"coordinator_acceptance":"scoped_review_with_explicit_source_actualfact_and_parent_holds","coordinator_review":"[internal evidence reference]"},{"topic":"§30 small-servicer/reverse/qualified-lender limits","researcher_record":{"Assigned subquestion / major branch":"§30 small-servicer/reverse/qualified-lender limits","Status":"A","Claim / example links":"C008; E07","Exact missing authority or facts":"Actual exemption status not determined","Next bounded permissible investigation":"None needed to show these are not blanket §33 exemptions"},"raw_table_index":11,"coordinator_acceptance":"scoped_review_with_explicit_source_actualfact_and_parent_holds","coordinator_review":"[internal evidence reference]"},{"topic":"Principal residence versus broader §33 scope","researcher_record":{"Assigned subquestion / major branch":"Principal residence versus broader §33 scope","Status":"A","Claim / example links":"C008","Exact missing authority or facts":"Actual product/property facts","Next bounded permissible investigation":"No property investigation"},"raw_table_index":11,"coordinator_acceptance":"scoped_review_with_explicit_source_actualfact_and_parent_holds","coordinator_review":"[internal evidence reference]"},{"topic":"Open-end product divergence","researcher_record":{"Assigned subquestion / major branch":"Open-end product divergence","Status":"A/P","Claim / example links":"C008, C039; E07","Exact missing authority or facts":"Any broader direct statutory-claim issue is not adjudicated","Next bounded permissible investigation":"If later authorized, examine public authority on that precise statutory/regulatory issue"},"raw_table_index":11,"coordinator_acceptance":"scoped_review_with_explicit_source_actualfact_and_parent_holds","coordinator_review":"[internal evidence reference]"},{"topic":"Servicer versus master/subservicer","researcher_record":{"Assigned subquestion / major branch":"Servicer versus master/subservicer","Status":"A/U","Claim / example links":"C009, C012, C019; E08","Exact missing authority or facts":"Actual functions/agreement and payment changes","Next bounded permissible investigation":"Generic authority only; no provider investigation"},"raw_table_index":11,"coordinator_acceptance":"scoped_review_with_explicit_source_actualfact_and_parent_holds","coordinator_review":"[internal evidence reference]"},{"topic":"Statutory and regulatory named-actor exclusions","researcher_record":{"Assigned subquestion / major branch":"Statutory and regulatory named-actor exclusions","Status":"A/U","Claim / example links":"C010–C011","Exact missing authority or facts":"Applicable actor/function/distress facts","Next bounded permissible investigation":"No entity-status query"},"raw_table_index":11,"coordinator_acceptance":"scoped_review_with_explicit_source_actualfact_and_parent_holds","coordinator_review":"[internal evidence reference]"},{"topic":"Confirmed successor definition","researcher_record":{"Assigned subquestion / major branch":"Confirmed successor definition","Status":"A/U","Claim / example links":"C014–C015; E12","Exact missing authority or facts":"Qualifying transfer and confirmation","Next bounded permissible investigation":"No property/identity investigation"},"raw_table_index":11,"coordinator_acceptance":"scoped_review_with_explicit_source_actualfact_and_parent_holds","coordinator_review":"[internal evidence reference]"},{"topic":"Successor acknowledgment exceptions","researcher_record":{"Assigned subquestion / major branch":"Successor acknowledgment exceptions","Status":"A/U","Claim / example links":"C016–C017, C058; E12","Exact missing authority or facts":"Compliance, assumption, acknowledgment/revocation facts","Next bounded permissible investigation":"None for generic conditions"},"raw_table_index":11,"coordinator_acceptance":"scoped_review_with_explicit_source_actualfact_and_parent_holds","coordinator_review":"[internal evidence reference]"},{"topic":"Both servicers’ duties","researcher_record":{"Assigned subquestion / major branch":"Both servicers’ duties","Status":"A","Claim / example links":"C018; E01","Exact missing authority or facts":"Actual notice performance","Next bounded permissible investigation":"No records work"},"raw_table_index":11,"coordinator_acceptance":"scoped_review_with_explicit_source_actualfact_and_parent_holds","coordinator_review":"[internal evidence reference]"},{"topic":"Affiliate/merger/master exclusions","researcher_record":{"Assigned subquestion / major branch":"Affiliate/merger/master exclusions","Status":"A/U","Claim / example links":"C019; E08","Exact missing authority or facts":"Listed category and all four unchanged features","Next bounded permissible investigation":"No corporate investigation"},"raw_table_index":11,"coordinator_acceptance":"scoped_review_with_explicit_source_actualfact_and_parent_holds","coordinator_review":"[internal evidence reference]"},{"topic":"FHA-specific notice exception","researcher_record":{"Assigned subquestion / major branch":"FHA-specific notice exception","Status":"A/U","Claim / example links":"C020","Exact missing authority or facts":"Exact assignment/actor facts","Next bounded permissible investigation":"No loan/provider investigation"},"raw_table_index":11,"coordinator_acceptance":"scoped_review_with_explicit_source_actualfact_and_parent_holds","coordinator_review":"[internal evidence reference]"},{"topic":"Separate and combined servicing clocks","researcher_record":{"Assigned subquestion / major branch":"Separate and combined servicing clocks","Status":"A","Claim / example links":"C021; E03","Exact missing authority or facts":"Actual event and dispatch dates","Next bounded permissible investigation":"Keep triggered periods; no calendar invented"},"raw_table_index":11,"coordinator_acceptance":"scoped_review_with_explicit_source_actualfact_and_parent_holds","coordinator_review":"[internal evidence reference]"},{"topic":"Extended timing events","researcher_record":{"Assigned subquestion / major branch":"Extended timing events","Status":"A/U","Claim / example links":"C022; E14","Exact missing authority or facts":"Enumerated preceding event","Next bounded permissible investigation":"No bankruptcy/corporate/docket query"},"raw_table_index":11,"coordinator_acceptance":"scoped_review_with_explicit_source_actualfact_and_parent_holds","coordinator_review":"[internal evidence reference]"},{"topic":"Settlement timing","researcher_record":{"Assigned subquestion / major branch":"Settlement timing","Status":"A/U","Claim / example links":"C023; E14","Exact missing authority or facts":"Compliant settlement notice facts","Next bounded permissible investigation":"No closing-document request"},"raw_table_index":11,"coordinator_acceptance":"scoped_review_with_explicit_source_actualfact_and_parent_holds","coordinator_review":"[internal evidence reference]"},{"topic":"Mailing versus receipt","researcher_record":{"Assigned subquestion / major branch":"Mailing versus receipt","Status":"A/U","Claim / example links":"C024–C025; E04–E05","Exact missing authority or facts":"Actual dispatch, addresses, electronic conditions","Next bounded permissible investigation":"No evidence collection"},"raw_table_index":11,"coordinator_acceptance":"scoped_review_with_explicit_source_actualfact_and_parent_holds","coordinator_review":"[internal evidence reference]"},{"topic":"Business/calendar-day distinctions","researcher_record":{"Assigned subquestion / major branch":"Business/calendar-day distinctions","Status":"A","Claim / example links":"C021, C030, C045","Exact missing authority or facts":"No dates supplied","Next bounded permissible investigation":"No arithmetic needed"},"raw_table_index":11,"coordinator_acceptance":"scoped_review_with_explicit_source_actualfact_and_parent_holds","coordinator_review":"[internal evidence reference]"},{"topic":"Required payment/contact/address/effective-date content","researcher_record":{"Assigned subquestion / major branch":"Required payment/contact/address/effective-date content","Status":"A","Claim / example links":"C026–C028","Exact missing authority or facts":"Actual document text absent","Next bounded permissible investigation":"Blank audit supplied"},"raw_table_index":11,"coordinator_acceptance":"scoped_review_with_explicit_source_actualfact_and_parent_holds","coordinator_review":"[internal evidence reference]"},{"topic":"Current MS-2 complete text","researcher_record":{"Assigned subquestion / major branch":"Current MS-2 complete text","Status":"A","Claim / example links":"C028–C029, C062","Exact missing authority or facts":"None as to parsed model text","Next bounded permissible investigation":"None needed for text identification"},"raw_table_index":11,"coordinator_acceptance":"scoped_review_with_explicit_source_actualfact_and_parent_holds","coordinator_review":"[internal evidence reference]"},{"topic":"MS-2 pixel/layout inspection","researcher_record":{"Assigned subquestion / major branch":"MS-2 pixel/layout inspection","Status":"P","Claim / example links":"S011–S012; failure log","Exact missing authority or facts":"Inspectable image content was not exposed by screenshot responses","Next bounded permissible investigation":"Obtain inspectable images of only the two official model pages through an authorized public-web capability"},"raw_table_index":11,"coordinator_acceptance":"scoped_review_with_explicit_source_actualfact_and_parent_holds","coordinator_review":"[internal evidence reference]"},{"topic":"Historical/proposed model distinction","researcher_record":{"Assigned subquestion / major branch":"Historical/proposed model distinction","Status":"A/P","Claim / example links":"C030, C062","Exact missing authority or facts":"No complete historical form reconstruction attempted","Next bounded permissible investigation":"Only if a historical-version question becomes necessary"},"raw_table_index":11,"coordinator_acceptance":"scoped_review_with_explicit_source_actualfact_and_parent_holds","coordinator_review":"[internal evidence reference]"},{"topic":"60-day trigger versus notice date","researcher_record":{"Assigned subquestion / major branch":"60-day trigger versus notice date","Status":"A","Claim / example links":"C013, C032","Exact missing authority or facts":"Actual effective date","Next bounded permissible investigation":"No actual calculation"},"raw_table_index":11,"coordinator_acceptance":"scoped_review_with_explicit_source_actualfact_and_parent_holds","coordinator_review":"[internal evidence reference]"},{"topic":"Late-fee/late-treatment restriction","researcher_record":{"Assigned subquestion / major branch":"Late-fee/late-treatment restriction","Status":"A/U","Claim / example links":"C033","Exact missing authority or facts":"Particular fee/classification and payment linkage","Next bounded permissible investigation":"Full reporting/remedy work held"},"raw_table_index":11,"coordinator_acceptance":"scoped_review_with_explicit_source_actualfact_and_parent_holds","coordinator_review":"[internal evidence reference]"},{"topic":"Forwarding/return and recipient notification","researcher_record":{"Assigned subquestion / major branch":"Forwarding/return and recipient notification","Status":"A/U","Claim / example links":"C034; E13","Exact missing authority or facts":"Receipt/handling/notification facts; contextual promptness","Next bounded permissible investigation":"Generic authority on “promptly” only if a later narrow question requires it"},"raw_table_index":11,"coordinator_acceptance":"scoped_review_with_explicit_source_actualfact_and_parent_holds","coordinator_review":"[internal evidence reference]"},{"topic":"Grace period versus contract modification","researcher_record":{"Assigned subquestion / major branch":"Grace period versus contract modification","Status":"A/U","Claim / example links":"C035","Exact missing authority or facts":"Actual contractual terms","Next bounded permissible investigation":"Contract analysis held"},"raw_table_index":11,"coordinator_acceptance":"scoped_review_with_explicit_source_actualfact_and_parent_holds","coordinator_review":"[internal evidence reference]"},{"topic":"Sent-but-unreceived payment","researcher_record":{"Assigned subquestion / major branch":"Sent-but-unreceived payment","Status":"A/U","Claim / example links":"C036; E05","Exact missing authority or facts":"Receipt unknown","Next bounded permissible investigation":"Retain unknown"},"raw_table_index":11,"coordinator_acceptance":"scoped_review_with_explicit_source_actualfact_and_parent_holds","coordinator_review":"[internal evidence reference]"},{"topic":"Partial payment","researcher_record":{"Assigned subquestion / major branch":"Partial payment","Status":"A/U","Claim / example links":"C037; E06","Exact missing authority or facts":"Shortfall, policy, tolerance, application","Next bounded permissible investigation":"Full payment-crediting/accounting analysis held"},"raw_table_index":11,"coordinator_acceptance":"scoped_review_with_explicit_source_actualfact_and_parent_holds","coordinator_review":"[internal evidence reference]"},{"topic":"§1641(g) statute and §39 product difference","researcher_record":{"Assigned subquestion / major branch":"§1641(g) statute and §39 product difference","Status":"A","Claim / example links":"C038–C041","Exact missing authority or facts":"No actual product facts","Next bounded permissible investigation":"None for text comparison"},"raw_table_index":11,"coordinator_acceptance":"scoped_review_with_explicit_source_actualfact_and_parent_holds","coordinator_review":"[internal evidence reference]"},{"topic":"Posted §39 scope-comment inconsistency","researcher_record":{"Assigned subquestion / major branch":"Posted §39 scope-comment inconsistency","Status":"A/P","Claim / example links":"C039","Exact missing authority or facts":"Complete publisher correction history not audited","Next bounded permissible investigation":"Check official correction/amendment publications if needed"},"raw_table_index":11,"coordinator_acceptance":"scoped_review_with_explicit_source_actualfact_and_parent_holds","coordinator_review":"[internal evidence reference]"},{"topic":"Covered person/legal-title/frequency","researcher_record":{"Assigned subquestion / major branch":"Covered person/legal-title/frequency","Status":"A/U","Claim / example links":"C042","Exact missing authority or facts":"Actual title acquisition and acquisition frequency","Next bounded permissible investigation":"No owner/entity/loan roster investigation"},"raw_table_index":11,"coordinator_acceptance":"scoped_review_with_explicit_source_actualfact_and_parent_holds","coordinator_review":"[internal evidence reference]"},{"topic":"Beneficial/security interest and administrative convenience","researcher_record":{"Assigned subquestion / major branch":"Beneficial/security interest and administrative convenience","Status":"A/U","Claim / example links":"C043","Exact missing authority or facts":"Actual interest acquired and purpose","Next bounded permissible investigation":"Assignment/title work held"},"raw_table_index":11,"coordinator_acceptance":"scoped_review_with_explicit_source_actualfact_and_parent_holds","coordinator_review":"[internal evidence reference]"},{"topic":"Ownership affiliate/merger branch","researcher_record":{"Assigned subquestion / major branch":"Ownership affiliate/merger branch","Status":"A/U","Claim / example links":"C044","Exact missing authority or facts":"Different-entity acquisition facts","Next bounded permissible investigation":"No corporate-record query"},"raw_table_index":11,"coordinator_acceptance":"scoped_review_with_explicit_source_actualfact_and_parent_holds","coordinator_review":"[internal evidence reference]"},{"topic":"Ownership timing and date election","researcher_record":{"Assigned subquestion / major branch":"Ownership timing and date election","Status":"A/U","Claim / example links":"C045","Exact missing authority or facts":"Recognized acquisition/transfer date","Next bounded permissible investigation":"No books-and-records request"},"raw_table_index":11,"coordinator_acceptance":"scoped_review_with_explicit_source_actualfact_and_parent_holds","coordinator_review":"[internal evidence reference]"},{"topic":"Ownership recipient/form/combination","researcher_record":{"Assigned subquestion / major branch":"Ownership recipient/form/combination","Status":"A/U","Claim / example links":"C046","Exact missing authority or facts":"Actual liable-recipient and delivery facts","Next bounded permissible investigation":"No individualized compliance finding"},"raw_table_index":11,"coordinator_acceptance":"scoped_review_with_explicit_source_actualfact_and_parent_holds","coordinator_review":"[internal evidence reference]"},{"topic":"All-interest disposition exception","researcher_record":{"Assigned subquestion / major branch":"All-interest disposition exception","Status":"A/U","Claim / example links":"C047; E09","Exact missing authority or facts":"Retained/disposed interest and timing","Next bounded permissible investigation":"No chain-of-title investigation"},"raw_table_index":11,"coordinator_acceptance":"scoped_review_with_explicit_source_actualfact_and_parent_holds","coordinator_review":"[internal evidence reference]"},{"topic":"Repurchase exception","researcher_record":{"Assigned subquestion / major branch":"Repurchase exception","Status":"A/U","Claim / example links":"C048","Exact missing authority or facts":"Repurchase obligation and recognition facts","Next bounded permissible investigation":"Generic contract-law expansion held"},"raw_table_index":11,"coordinator_acceptance":"scoped_review_with_explicit_source_actualfact_and_parent_holds","coordinator_review":"[internal evidence reference]"},{"topic":"Partial-interest/no-contact-change exception","researcher_record":{"Assigned subquestion / major branch":"Partial-interest/no-contact-change exception","Status":"A/U","Claim / example links":"C049; E11","Exact missing authority or facts":"Interest and authorized-party changes","Next bounded permissible investigation":"No provider/agency investigation"},"raw_table_index":11,"coordinator_acceptance":"scoped_review_with_explicit_source_actualfact_and_parent_holds","coordinator_review":"[internal evidence reference]"},{"topic":"Sequential transfers","researcher_record":{"Assigned subquestion / major branch":"Sequential transfers","Status":"A/U","Claim / example links":"C050; E09","Exact missing authority or facts":"Sequence, timing, availability of future-date information","Next bounded permissible investigation":"No record search"},"raw_table_index":11,"coordinator_acceptance":"scoped_review_with_explicit_source_actualfact_and_parent_holds","coordinator_review":"[internal evidence reference]"},{"topic":"Joint acquisitions","researcher_record":{"Assigned subquestion / major branch":"Joint acquisitions","Status":"A/U","Claim / example links":"C051; E10","Exact missing authority or facts":"Same agreement/concert, completion dates","Next bounded permissible investigation":"No transaction-record search"},"raw_table_index":11,"coordinator_acceptance":"scoped_review_with_explicit_source_actualfact_and_parent_holds","coordinator_review":"[internal evidence reference]"},{"topic":"Owner/agent/recording content","researcher_record":{"Assigned subquestion / major branch":"Owner/agent/recording content","Status":"A/U","Claim / example links":"C052–C055, C059","Exact missing authority or facts":"Actual notice, agency authority, recording facts","Next bounded permissible investigation":"No recording search or identifiers"},"raw_table_index":11,"coordinator_acceptance":"scoped_review_with_explicit_source_actualfact_and_parent_holds","coordinator_review":"[internal evidence reference]"},{"topic":"Partial-payment disclosure and transition dates","researcher_record":{"Assigned subquestion / major branch":"Partial-payment disclosure and transition dates","Status":"A","Claim / example links":"C056–C057","Exact missing authority or facts":"Actual applicable policy unknown","Next bounded permissible investigation":"No full payment-processing review"},"raw_table_index":11,"coordinator_acceptance":"scoped_review_with_explicit_source_actualfact_and_parent_holds","coordinator_review":"[internal evidence reference]"},{"topic":"Contact change without acquisition","researcher_record":{"Assigned subquestion / major branch":"Contact change without acquisition","Status":"A","Claim / example links":"C060; E11","Exact missing authority or facts":"Stipulated in example; actual event unknown","Next bounded permissible investigation":"Other update duties held"},"raw_table_index":11,"coordinator_acceptance":"scoped_review_with_explicit_source_actualfact_and_parent_holds","coordinator_review":"[internal evidence reference]"},{"topic":"Notice versus assignment/security/standing proof","researcher_record":{"Assigned subquestion / major branch":"Notice versus assignment/security/standing proof","Status":"A/X","Claim / example links":"C001, C061","Exact missing authority or facts":"Substantive documents and applicable law intentionally absent","Next bounded permissible investigation":"Parent-held investigation; not authorized here"},"raw_table_index":11,"coordinator_acceptance":"scoped_review_with_explicit_source_actualfact_and_parent_holds","coordinator_review":"[internal evidence reference]"},{"topic":"Full current-law/session-law lag audit","researcher_record":{"Assigned subquestion / major branch":"Full current-law/session-law lag audit","Status":"P","Claim / example links":"C063–C065; S023–S024","Exact missing authority or facts":"Direct eCFR bodies; verified 2026 annual §39; complete post-compilation update audit","Next bounded permissible investigation":"Retrieve official current bodies and bounded amendment/correction history"},"raw_table_index":11,"coordinator_acceptance":"scoped_review_with_explicit_source_actualfact_and_parent_holds","coordinator_review":"[internal evidence reference]"},{"topic":"Hypothetical branches","researcher_record":{"Assigned subquestion / major branch":"Hypothetical branches","Status":"A","Claim / example links":"E01–E14","Exact missing authority or facts":"No individual facts intended","Next bounded permissible investigation":"None"},"raw_table_index":11,"coordinator_acceptance":"scoped_review_with_explicit_source_actualfact_and_parent_holds","coordinator_review":"[internal evidence reference]"},{"topic":"Blank audit worksheet","researcher_record":{"Assigned subquestion / major branch":"Blank audit worksheet","Status":"A","Claim / example links":"Section 6","Exact missing authority or facts":"All entries deliberately blank","Next bounded permissible investigation":"None"},"raw_table_index":11,"coordinator_acceptance":"scoped_review_with_explicit_source_actualfact_and_parent_holds","coordinator_review":"[internal evidence reference]"},{"topic":"Cases/opinions","researcher_record":{"Assigned subquestion / major branch":"Cases/opinions","Status":"X","Claim / example links":"Read log","Exact missing authority or facts":"No material opinion necessary for this text-focused component","Next bounded permissible investigation":"Published majority opinion only if a later narrow legal issue strictly requires it"},"raw_table_index":11,"coordinator_acceptance":"scoped_review_with_explicit_source_actualfact_and_parent_holds","coordinator_review":"[internal evidence reference]"},{"topic":"State/local/tribal/foreign/product/contract closure","researcher_record":{"Assigned subquestion / major branch":"State/local/tribal/foreign/product/contract closure","Status":"X","Claim / example links":"C031, C061; parent holds","Exact missing authority or facts":"All jurisdictional and actual-contract predicates absent","Next bounded permissible investigation":"Separate authorization and bounded scope required"},"raw_table_index":11,"coordinator_acceptance":"scoped_review_with_explicit_source_actualfact_and_parent_holds","coordinator_review":"[internal evidence reference]"},{"topic":"Eligibility, liability, remedies, litigation decision","researcher_record":{"Assigned subquestion / major branch":"Eligibility, liability, remedies, litigation decision","Status":"X","Claim / example links":"C061, C066","Exact missing authority or facts":"Not investigated or decided","Next bounded permissible investigation":"Remains parent-held"},"raw_table_index":11,"coordinator_acceptance":"scoped_review_with_explicit_source_actualfact_and_parent_holds","coordinator_review":"[internal evidence reference]"}],"annotations":{"at":"2026-10-27T21:52:36.128069+00:00","review":"[internal evidence reference]","disposition":"accepted_with_limits_conditional_federal_transfer_notice_framework","first_scoped_review_complete":true,"raw_originals_unchanged":true,"independent_review":false,"material_correction_required":false,"whole_text_and_all_tables_reviewed":true,"no_component_or_parent_acceptance":true,"source_currentness_historical_edition_and_actual_facts_held":true},"corrections":[],"resolved_corrections":[],"review_history":[{"id":"R006-P01-currentness-history-and-application-holds-20261027","status":"bounded_framework_reviewed_parent_and_evidence_holds_remain","at":"2026-10-27T21:52:36.128069+00:00"}]}