Starting March 1, 2017, the Kentucky Department of Financial Institutions will require “master servicers” as well as “sub servicers”, not exempt under KRS 286.8-020, to be licensed as mortgage companies under the Kentucky Mortgage Licensing and Regulation Act. The Department considers a “master servicer” to be any entity or individual that owns the right to perform servicing of a mortgage loan. A master servicer typically reserves the legal right to either perform the servicing itself or to do so through a sub servicer. Thus, this interpretation includes a servicer that has the right to service loans in Kentucky but does so indirectly through a sub servicer. A “sub servicer” is an entity that does not own the right to perform servicing, but performs servicing on behalf of a master servicer, generally premised upon duties enumerated in a contract between the sub servicer and master servicer. The Department has indicated that servicers that are HUD-exempt entities and non-profit entities that fall within the KRS 286.8-020 exemption must still file an application with the Department in order to verify their exempt status.