The proposal states:
“The Bureau also is proposing to
exclude from consideration any
mortgage loan voluntarily serviced by a
small servicer for a creditor or assignee
that is not an affiliate of the servicer and
for which the servicer does not receive
any compensation or fees (‘‘charitably
serviced ’’ mortgage loans).”
https://www.gpo.gov/fdsys/pkg/FR-2013-05-02/pdf/2013-09750.pdf
Therefore, if this portion of the proposal becomes final, if you don’t receive compensation or fees for the servicing of these loans and you otherwise qualify for the exemption, you wouldn’t be excluded from the exemption based on servicing these loans.