The Consumer Mortgage Coalition recently told the CFPB one way to improve the bureau’s proposed regulation having to do with “successors in interest” is to eliminate the requirement to make successorship determinations when they are not necessary. The CFPB’s goal in this regard is to make loss mitigation more available to successors. However, the CMC said in a recent memo to the bureau that loss mitigation does not always require a successorship determination. “If a claimant ... cannot keep the loan reasonably free of default and the servicer will not pursue due-on-sale enforcement, there is no per se need to determine successorship,” said the trade group. “Of course, there may be a need to determine loss mitigation. Loss mitigation may ...