At least 22 states require mortgage servicers to follow early intervention, loss mitigation, and foreclosure process standards. These state requirements often serve as a bridge between consumer protection in financial services and property law protections under state law. In 2024, the CFPB proposed revisions to the mortgage servicing rules under RESPA/Regulation X that would: (1) remove most of the application-based loss mitigation provisions from Regulation X; (2) require servicers to provide foreclosure protections as soon as a borrower requests assistance; and (3) impose new language access obligations for borrowers with limited English proficiency (“LEP”). These proposed changes create uncertainty and ambiguity regarding how processes and protections under various state laws will interact with the federal framework going forward.