April 19, 2013 at 3:14 pm EDT
#3114
Member
We are in question on whether or not we fall under the small servicer exemption. We have far fewer than 5,000 mortgage loans, but we take payments for a “scholarship loan fund” started by a local attorney. We receive payments, but we do not take the action of a creditor or do any IRS reporting. We do not fund the loans, however some of them are secured by the borrower’s principal residence. Thoughts?