The Consumer Mortgage Coalition and the Mortgage Servicers Working Group asked the CFPB for guidance on how to comply with bankruptcy-related provisions when a confirmed successor-in-interest, who is not legally a borrower, has filed a bankruptcy petition. Under Regulations X and Z, these successors will be considered borrowers. Their inquiry came in response to the bureau’s request for comment on its plan to assess its 2013 mortgage servicing rules. One question the industry representatives had is whether the Fair Debt Collection Practices Act applies to the mortgage servicing rule’s early intervention requirements.They note that Section 1024.39(c) of Reg X provides some exemption from early intervention written notices if any borrower on the loan sends an FDCPA cease-communication notice “with ...