The Real Estate Settlement Procedures Act (“RESPA”) and Regulation X require that federally related mortgage loan “servicers” comply with certain loss mitigation procedures. See, e.g., 12 U.S.C. § 2605; 12 C.F.R. § 1024.41. In particular, servicers are required to evaluate “all loss mitigation options available to the borrower” if a “complete loss mitigation application” is received “more than 37 days before a foreclosure sale.” See 12 C.F.R. § 1024.41(c). The United States Court of Appeals for the Fifth Circuit recently confirmed that those obligations are only applicable to the “servicer,” and that an originating lender or assignee of the loan are not “vicariously” liable for any such violations by the servicer. See Christiana Trust v. Riddle, No. 17-11429, 2018 WL 6715882 (5th Cir. Dec. 21, 2018).