See 3500.21(a) -
Mortgage servicing loan means a federally related mortgage loan, as that term is defined in Sec. 3500.2, subject to the exemptions in Sec. 3500.5, when the mortgage loan is secured by a first lien. The definition does not include subordinate lien loans or open-end lines of credit (home equity plans) covered by the Truth in Lending Act and Regulation Z, including open-end lines of credit secured by a first lien.
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The opinions expressed are mine and they are not to be taken as legal advice.