The Consumer Financial Protection Bureau’s new mortgage servicing rules contain exemptions for small servicers, defined as those with 5,000 or fewer mortgages.

But smaller loan servicers cannot escape scrutiny entirely, says Dinsmore & Shohl attorney David Thomas, in a report posted on the Association of Corporate Counsel website.

He points out:

“Even if a community bank qualifies as a small servicer, it cannot ignore the Mortgage Servicing Rules altogether as some of the new rules apply to all entities servicing mortgage loans, regardless of size. This article will focus on summarizing a handful of the Mortgage Servicing Rules which apply to “small servicers” such as community banks that service their own loans.”