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#1488048 - 12/31/10 12:53 PM Servicemember notice - correct language.
burgess Online
Diamond Poster

Registered: 01/27/04
Posts: 1260
Servicemembers notice. i see links to HUD http://www.hud.gov/offices/adm/hudclips/forms/files/92070.pdf
for a sample notice.
But do i understand correctly that the sample notice is incorrect and should be changed - the 90 days becomes 9 months and the 6% rate language should add "effective for a year after leaving the service"??
Is there some sample of this that we can use?
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Lending to Servicemembers
#1488123 - 12/31/10 02:29 PM Re: Servicemember notice - correct language. [Re: burgess]
ahkcompliance Online
Diamond Poster

Registered: 09/10/08
Posts: 1811
Loc: Midwest
We made those changes last year when the provisions were passed. We have been examined and they looked for those changes to make sure we were compliant with them. I have not seen anything from HUD.

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#1488251 - 01/01/11 03:46 PM Re: Servicemember notice - correct language. [Re: ahkcompliance]
ahou Offline
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Registered: 08/15/02
Posts: 2724
Don't these changes sunset after 12-31-10?
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#1488314 - 01/03/11 10:06 AM Re: Servicemember notice - correct language. [Re: ahou]
John Burnett Offline
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Registered: 10/27/00
Posts: 30972
Loc: Cape Cod
No. The president signed on 12/29 the "Helping Heroes Keep Their Homes Act" which extended the 90 days ==> 9 months changes through 12/31/12.

The provision that extended the 6% cap on mortgage and deed of trust loans to the term of service plus one year following service is permanent. It only applies to mortgage and deed of trust loans.


Edited by John Burnett (01/03/11 10:07 AM)
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#1488321 - 01/03/11 10:27 AM Re: Servicemember notice - correct language. [Re: John Burnett]
burgess Online
Diamond Poster

Registered: 01/27/04
Posts: 1260
So (why is this so difficult for me to get through my head) the sample notice on the HUD website is wrong. I need to amend it by:
1. substituting 9 months for 90 days. and
2. saying something about this being temp thru 12.31.2012

BUT

I don't change the language about the 6% being effective during military service, since the 1 year thereafter language only applies to mortgage loans.
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#1488441 - 01/03/11 12:30 PM Re: Servicemember notice - correct language. [Re: burgess]
John Burnett Offline
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Registered: 10/27/00
Posts: 30972
Loc: Cape Cod
Uh, HUD is concerned with mortgages, right? So yes, the one-year addition protection language would apply.
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John S Burnett
BankersOnline.com

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#1488458 - 01/03/11 12:51 PM Re: Servicemember notice - correct language. [Re: John Burnett]
burgess Online
Diamond Poster

Registered: 01/27/04
Posts: 1260
sO - I guess we would change the notice to read:
• The SCRA states that a debt incurred by a servicemember, or servicemember and spouse jointly, prior to entering military service shall not bear interest at a rate above 6 percent
during the period of military service AND FOR ONE YEAR AFTER LEAVING THE SERVICE. • The SCRA states that in a legal action to enforce a debt against real estate that is filed during, or within NINE MONTHS after the servicemember’s military service, a court may stop the proceedings for a period of time, or adjust the debt. In addition, the sale, foreclosure, or seizure of real estate shall not be valid if it occurs during, or within NINE MONTHS after the servicemember’s military service unless the creditor has obtained a court order approving the
sale, foreclosure, or seizure of the real estate.
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#1488604 - 01/03/11 03:36 PM Re: Servicemember notice - correct language. [Re: burgess]
ahkcompliance Online
Diamond Poster

Registered: 09/10/08
Posts: 1811
Loc: Midwest
This is what our notice says...

The SCRA states that a debt incurred by a servicemember, or servicemember and spouse jointly, prior to entering military service shall not bear interest at a rate above 6 percent
during the period of military service. In the case of a mortgage loan, the 6 percent cap extends to one year following the end of the military service.

We also stay 9 months as well.


Edited by ahkcompliance (01/03/11 03:37 PM)

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#1488824 - 01/04/11 09:00 AM Re: Servicemember notice - correct language. [Re: ahkcompliance]
burgess Online
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Registered: 01/27/04
Posts: 1260
Ahkcompliance - thanks, that was what i was looking for, i appreciate it.
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#1489363 - 01/04/11 03:43 PM Re: Servicemember notice - correct language. [Re: burgess]
jross Offline
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Registered: 12/23/09
Posts: 184
Loc: TX
While reviewing our SCRA Policy I came across this statement,

The SCRA requires creditors to provide notice to all homeowners in default of the mortgage and foreclosure rights of servicemembers and their dependents under the SCRA within 45 days from the date that a missed payment was due and includes a required format.

Are we required to give this notice to all homeowners or just those who have given us notice that they are on active duty?
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#1489476 - 01/04/11 04:42 PM Re: Servicemember notice - correct language. [Re: jross]
ahkcompliance Online
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Registered: 09/10/08
Posts: 1811
Loc: Midwest
We give to all since we don't know who may or may not be on active duty.

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#1489502 - 01/04/11 04:59 PM Re: Servicemember notice - correct language. [Re: ahkcompliance]
jross Offline
100 Club

Registered: 12/23/09
Posts: 184
Loc: TX
We do not have many military customers (less than 5) and have only been notified once within the last 10 years. This is all still relatively new to me since we do not use it. That being said, we still need to comply with the law and if we need to make changes now is the best time.
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#1489639 - 01/05/11 08:47 AM Re: Servicemember notice - correct language. [Re: jross]
Dan Persfull Offline
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Registered: 08/28/02
Posts: 41142
Loc: Bloomington, IN
You should provide it to all. The purpose of the notice is to notify the consumer of their potential rights under the SCRA if they are a servicemember. Not all servicemembers will notify you they are on active duty so you have no way of knowing which consumers may be covered by the SCRA.
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#1493264 - 01/11/11 02:00 PM Re: Servicemember notice - correct language. [Re: Dan Persfull]
complygirl Offline
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Registered: 10/29/04
Posts: 794
Loc: midwest
So is this the correct SCRA notice verbiage for the "9 months" amendment:

" The SCRA states that in a legal action to enforce a debt against real estate that is filed during, or within 9 months after the servicemember’s military service, a court may stop the proceedings for a period of time, or adjust the debt. In addition, the sale, foreclosure, or seizure of real estate shall not be valid if it occurs during, or within 9 months after the servicemember’s military service unless the creditor has obtained a court order approving the sale, foreclosure, or seizure of the real estate." (Emphasis added - just to show specific text that was changed)

Both previous references to 90 days should be updated to 9 months? Just wanted to doublecheck this. Thanks.

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#1493400 - 01/11/11 03:15 PM Re: Servicemember notice - correct language. [Re: complygirl]
ahkcompliance Online
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Registered: 09/10/08
Posts: 1811
Loc: Midwest
That is correct.

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#1494050 - 01/12/11 01:06 PM Re: Servicemember notice - correct language. [Re: ahkcompliance]
Summer101 Offline
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Registered: 06/13/01
Posts: 577
Is it really okay to amend the language in the notice if the regulation (12 USC 1701x(c)(5)(A)(ii)(IV)) says to provide a notice "written in plain English by the Secretary of Housing and Urban Development, in consultation with the Secretary of Defense and the Secretary of the Treasury"?

This seems very similar to the requirement to use an unmodified version of FDIC's notice of unlimited insurance coverage even though it currently says IOLTAs are not included.

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#1494740 - 01/13/11 01:02 PM Re: Servicemember notice - correct language. [Re: Summer101]
John Burnett Offline
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Registered: 10/27/00
Posts: 30972
Loc: Cape Cod
The problem is that HUD isn't the agency that will examine you for compliance, and it's not known for staying on top of this particular issue. Your regulator can cite you for not updating the wording, and make it stick.

As for the IOLTA thing, no agency other than the FDIC will worry about that notice, and the FDIC knows about the problem.
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#1496477 - 01/18/11 01:48 PM Re: Servicemember notice - correct language. [Re: John Burnett]
NotDoneYet Online
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Registered: 07/28/10
Posts: 427
Loc: PA
I just came across an updated version under HUD and it appears to have the correct language, except the one-yr period doesn't specify mortgage related loans.

http://www.hud.gov/offices/adm/hudclips/forms/files/92070.pdf

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#1496522 - 01/18/11 02:29 PM Re: Servicemember notice - correct language. [Re: NotDoneYet]
NotDoneYet Online
Gold Star

Registered: 07/28/10
Posts: 427
Loc: PA
The expiration date is 7/31/2012 on this new notice, but wasn't it extended to 12/31/2012? Do you think it would be okay to fix the expiration date and add language to the "one year after service" that it applies to mortgage related loans?

On the other hand, how often are notices we are given to use not exactly perfect, but we still use them for safe harbor purposes.


Edited by jcaldwell (01/18/11 02:30 PM)

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#1500256 - 01/26/11 08:41 AM Re: Servicemember notice - correct language. [Re: NotDoneYet]
Compliance Rules Offline
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Registered: 06/23/06
Posts: 1140
Loc: South
This morning's ABA newsbytes.

HUD Updates SCRA Notice
The Department of Housing and Urban Development has updated its Servicemembers Civil Relief Act notice -- new form HUD-92070 -- to reflect the expanded protections required by the Housing and Economic Recovery Act and Helping Heroes Keep Their Homes Act. Banks should begin using the new HUD notice immediately. The changes in the new notice are amendments to SCRA’s Section 527 (maximum rate of interest on debts incurred before military service) and Section 533 (mortgages and trust deeds) that provide military members with additional time under each of the two protections.

The new notice must be sent to all homeowners -- even those not in the military -- who are in default on a residential mortgage. It must be sent within 45 days from the date a missed payment was due, unless the homeowner pays the overdue amount before the expiration of the 45-day period.

http://www.hud.gov/offices/adm/hudclips/forms/files/92070.pdf


Edited by Compliance Rules (01/26/11 11:13 AM)

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#1500455 - 01/26/11 11:27 AM Re: Servicemember notice - correct language. [Re: Compliance Rules]
SMQ, CRCM Offline

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Loc: Between the lines
Is there a Word copy of this anywhere, or do we just have to retype to insert our info?
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#1500508 - 01/26/11 12:11 PM Re: Servicemember notice - correct language. [Re: SMQ, CRCM]
KC Danimal Offline
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Registered: 09/20/05
Posts: 922
Loc: Kansas City
Braincramp - what section of the law requires this notice?
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#1500514 - 01/26/11 12:20 PM Re: Servicemember notice - correct language. [Re: SMQ, CRCM]
Andy Z Online

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Registered: 10/27/00
Posts: 25295
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We'll have a Word version for you by the end of the day.
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AndyZ CRCM
My opinions are not necessarily my employers.
R+R-R=R+R
Rules and Regs minus Relationships equals Resentment and Rebellion. John Maxwell

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#1500518 - 01/26/11 12:25 PM Re: Servicemember notice - correct language. [Re: Andy Z]
SMQ, CRCM Offline

Power Poster

Registered: 04/09/01
Posts: 4544
Loc: Between the lines
Bravo!!! BOL to the rescue.
A true friend to the banks,
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#1500834 - 01/26/11 04:23 PM Re: Servicemember notice - correct language. [Re: SMQ, CRCM]
Andy Z Online

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Registered: 10/27/00
Posts: 25295
Loc: On the Net
http://www.bankersonline.com/tools/tools.html Newest Tools


There is a Word form that you can customize in the "Lender place your name here..." slot and the HUD form itself in PDF which is only really good for showing that the Word form conforms.


Edited by Andy Z (01/26/11 04:25 PM)
_________________________
AndyZ CRCM
My opinions are not necessarily my employers.
R+R-R=R+R
Rules and Regs minus Relationships equals Resentment and Rebellion. John Maxwell

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#1500900 - 01/26/11 05:06 PM Re: Servicemember notice - correct language. [Re: Andy Z]
SMQ, CRCM Offline

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Registered: 04/09/01
Posts: 4544
Loc: Between the lines
Done and sent to the printer, thanks Andy.
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The lower the latitude, the higher my attitude.

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#1500970 - 01/26/11 06:46 PM Re: Servicemember notice - correct language. [Re: SMQ, CRCM]
JoeCompliance
Unregistered


Does this notice get sent out on all Real Estate Loans or only 1-4 family homes? What about commercial RE of service members?

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#1501002 - 01/27/11 12:13 AM Re: Servicemember notice - correct language. [Re: Andy Z]
Bville Online
Platinum Poster

Registered: 05/08/01
Posts: 812
Loc: Out West
Has it always been a requirement to send this to all delinquent mortgage borrowers even those not in the military?

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#1501314 - 01/27/11 02:05 PM Re: Servicemember notice - correct language. [Re: Bville]
duplextx Offline
100 Club

Registered: 10/22/02
Posts: 144
Loc: Dallas, TX
Ditto Bville's question. When did this come about, and please don't tell me decades ago! Forever, we've been sending the Homeownership Counseling Notification, which was a generic mention of homeownership counseling on our delinquent, single family, residential dwelling secured past-due letters, with HUD's toll free telephone number (1-800-569-4287). Four years ago this month, we added a second sentence and a different toll free number (1-800-342-9647) for our military servicemembers and dependents.
What have I missed? Are we supposed to be sending the form HUD-92070 to ALL past due mortgage borrowers, regardless of any military affiliation, even though that form is strictly worded for the military?
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This is the sort of stuff that makes "retirement" look oh-so-very attractive!

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#1501400 - 01/27/11 03:27 PM Re: Servicemember notice - correct language. [Re: Bville]
Compliance Rules Offline
Diamond Poster

Registered: 06/23/06
Posts: 1140
Loc: South
Originally Posted By: Bville
Has it always been a requirement to send this to all delinquent mortgage borrowers even those not in the military?


You send it to all borrowers with loans secured by their principal residence because you will not know who all may be a servicemember or a dependants of servicemembers.

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#1501459 - 01/27/11 04:32 PM Re: Servicemember notice - correct language. [Re: Andy Z]
Bama Blondie Offline
100 Club

Registered: 09/24/10
Posts: 121
At my previous employer, in addition to sending the notice if loan was delinquent, we sent in origination package to make sure borrower was aware. Does anyone else do this? Thanks!

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#1501474 - 01/27/11 04:50 PM Re: Servicemember notice - correct language. [Re: Bama Blondie]
Deena Offline
Power Poster

Registered: 11/02/00
Posts: 2658
Loc: PA
Does anyone know if this notice has to be in this exact format? We have the language on a notice in our system, but I don't think it's in that format when it prints out.
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Opinions expressed are mine and not necessarily those of my employer.

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#1501494 - 01/27/11 04:59 PM Re: Servicemember notice - correct language. [Re: Deena]
Tesla Offline
Power Poster

Registered: 11/05/03
Posts: 3073
Is this effective immediately?
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It's not that I take life for granted. It's only that the good won't make it. Innocence dies, while Villany Thrives.

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#1501554 - 01/27/11 05:47 PM Re: Servicemember notice - correct language. [Re: Tesla]
Andy Z Online

10K Club

Registered: 10/27/00
Posts: 25295
Loc: On the Net
I don't find a press release or other information on it, but I believe it should be used immediately.

I don't know if vatiations on format are allowed or not. My guess is you must communicate this information and it should be clear and conspicuous.
_________________________
AndyZ CRCM
My opinions are not necessarily my employers.
R+R-R=R+R
Rules and Regs minus Relationships equals Resentment and Rebellion. John Maxwell

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#1501600 - 01/27/11 06:57 PM Re: Servicemember notice - correct language. [Re: duplextx]
Reads Regs Offline
Diamond Poster

Registered: 11/15/04
Posts: 2054
Here's a 2006 mortgagee letter from HUD about the SCRA notice. It said it had to be given out for conventional loans and not just FHA loans. http://www.hud.gov/offices/adm/hudclips/letters/mortgagee/files/06-28ML.doc This might give you some historical information about the requirement to provide the notice.
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Opinions expressed are my own and not necessarily those of my employer. They are not legal advice.

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#1501637 - 01/28/11 08:00 AM Re: Servicemember notice - correct language. [Re: Andy Z]
Deena Offline
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Registered: 11/02/00
Posts: 2658
Loc: PA
Originally Posted By: Andy Z
I don't know if vatiations on format are allowed or not. My guess is you must communicate this information and it should be clear and conspicuous.

Thanks, Andy. Our notice has the exact verbiage, but the format is not exactly the same. It's been reviewed by examiners in the past with no problem, but we all know what that's worth in the long run.
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Opinions expressed are mine and not necessarily those of my employer.

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#1501657 - 01/28/11 08:48 AM Re: Servicemember notice - correct language. [Re: NotDoneYet]
upstateNY Offline
Platinum Poster

Registered: 04/24/03
Posts: 933
Loc: New York State
Originally Posted By: jcaldwell
I just came across an updated version under HUD and it appears to have the correct language, except the one-yr period doesn't specify mortgage related loans.

http://www.hud.gov/offices/adm/hudclips/forms/files/92070.pdf


Just trying to get this straight. Even though the HUD form does not specify, the one year extension of the 6% rate only applies to mortgages , correct? Can we add language specifying that? Or would we be risking safe harbor?
Also, do we need to leave the headings as they are at the top? Or can we re-name and add out bank logo?

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#1501673 - 01/28/11 09:01 AM Re: Servicemember notice - correct language. [Re: upstateNY]
Dan Persfull Offline
10K Club

Registered: 08/28/02
Posts: 41142
Loc: Bloomington, IN
Upstate, this notice is only required for loans secured by a residential mortgage and HUD is assuming the notice is not sent to anyone else so they presumed referencing RE loan was not necessary.

But we all know in everyday life someone is going to say well we got this letter and it said that. We left the RE reference in our version.
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The opinions expressed are mine and they are not to be taken as legal advice.

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#1501684 - 01/28/11 09:18 AM Re: Servicemember notice - correct language. [Re: Dan Persfull]
upstateNY Offline
Platinum Poster

Registered: 04/24/03
Posts: 933
Loc: New York State
Thanks, that's my fear too. Even from a training standpoint, it's confusing. I'm going to put the reference to residential mortgages in to avoid this.

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#1501992 - 01/28/11 12:47 PM Re: Servicemember notice - correct language. [Re: upstateNY]
NHBankGuy Offline
Junior Member

Registered: 01/10/02
Posts: 35
Loc: Manchester, NH
Other than the dates, what actual changes to the form have been made?
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Opinions are not necessarily those of my employer and should not be construed as legal advice.

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#1502542 - 01/31/11 09:26 AM Re: Servicemember notice - correct language. [Re: burgess]
CarolinaComplian Offline
Member

Registered: 03/08/10
Posts: 67
Loc: good ol south
Going back to a previous question asked. Does this only apply to a consumer closed-end loan secured by the primary residence? Should the notice be given in the instance of a business loan secured by a guarantor's primary residence, or for a business loan secured by a residence to be used for investment purposes? The information just states residential mortgage.

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#1502617 - 01/31/11 11:00 AM Re: Servicemember notice - correct language. [Re: Andy Z]
KMK Offline
Member

Registered: 01/04/08
Posts: 69
Loc: Pennsylvania
Date in the lower right corner on the Word version looks like 2022. Typo?

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#1503289 - 02/01/11 11:07 AM Re: Servicemember notice - correct language. [Re: KMK]
John Burnett Offline
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Registered: 10/27/00
Posts: 30972
Loc: Cape Cod
That was a typo. It's being corrected.
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BankersOnline.com

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#1506602 - 02/08/11 11:26 AM Re: Servicemember notice - correct language. [Re: John Burnett]
JoeCompliance
Unregistered


The notice is in need of one more correction... and please do not hate me for typing this because I am well aware that what I am about to write makes no sense.
This was passed on to me by our FDIC examiner (here last week), AND I verified it with Military One.

Military One's Outside the US dialing instructions/# shoud be changed from
1-800-342-9647
to
1-800-3429-6477

I have never seen a number like that, and yes I have lived outside the US before. Go America (despite its growing bureaucracy)

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#1506810 - 02/08/11 03:09 PM Re: Servicemember notice - correct language. [Re: CarolinaComplian]
CrookedVulture Offline
100 Club

Registered: 07/18/08
Posts: 148
Originally Posted By: cbp0419
Going back to a previous question asked. Does this only apply to a consumer closed-end loan secured by the primary residence? Should the notice be given in the instance of a business loan secured by a guarantor's primary residence, or for a business loan secured by a residence to be used for investment purposes? The information just states residential mortgage.


I am wondering the same thing. Does anyone have any guidance?

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#1506844 - 02/08/11 03:34 PM Re: Servicemember notice - correct language. [Re: Andy Z]
ksm Offline
Gold Star

Registered: 05/20/03
Posts: 288
Loc: Midwest
In the fourth section, I will add the name and address of our bank. They also list contact information, but it does not make sense for them to provide a written request by phone. Do you add your website?

We have to manually type this notice so it prints on the back of our notices. Do we need the OMB, expiration date, HUD form number and revision date?

Is there any type of grace period or do we need to send new notices to the customers who received the new notice since these changes were signed into law? Since the new form came out?

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#1509506 - 02/12/11 01:29 AM Re: Servicemember notice - correct language. [Re: ksm]
Andy Z Online

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Registered: 10/27/00
Posts: 25295
Loc: On the Net
HUD called me back and the OMB info, as an example, is a part of what's new. I believe it should be included. They offered no real information on when it was to be used, but I would change out my old notices ASAP.

Joe - where did you get the new number for outside the US? I might add it, but I'd be hesitant to replace it simply because it varies from the prescribed notice. There might be a plan to add that number that was published.
_________________________
AndyZ CRCM
My opinions are not necessarily my employers.
R+R-R=R+R
Rules and Regs minus Relationships equals Resentment and Rebellion. John Maxwell

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#1509692 - 02/14/11 10:43 AM Re: Servicemember notice - correct language. [Re: Andy Z]
Dan Persfull Offline
10K Club

Registered: 08/28/02
Posts: 41142
Loc: Bloomington, IN
Not sure if it's been corrected but if I recall correctly when these notices first came out the 1-800-3429-6477 phone number (or one of them) connected you to a very "friendly" operator.
_________________________
The opinions expressed are mine and they are not to be taken as legal advice.

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#1509938 - 02/14/11 03:14 PM Re: Servicemember notice - correct language. [Re: Dan Persfull]
JoeCompliance
Unregistered


I was given this number by our examiners last week. They told me HUD got it wrong. I did not believe that the number that they gave was actually a phone number. So, in addition, I double checked with Military One (the people that the number is for). The lady at Military One was herself suprised, but she said that the number with the extra 7 is the number to call when calling from overseas.

In terms of the "friendly" call, the FDIC examiner said that the "friendly" ladies were who you reached if you did not add the extra 7.

-Just doin what I am told

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#1510229 - 02/15/11 10:59 AM Re: Servicemember notice - correct language. [Re: ]
Andy Z Online

10K Club

Registered: 10/27/00
Posts: 25295
Loc: On the Net
Don't you love it when the examiner contradicts the prescribed form. Srt of puts you between a rock and a hard place.

FWIW I am trying to do some verifications with HUD on this.
_________________________
AndyZ CRCM
My opinions are not necessarily my employers.
R+R-R=R+R
Rules and Regs minus Relationships equals Resentment and Rebellion. John Maxwell

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#1510239 - 02/15/11 11:14 AM Re: Servicemember notice - correct language. [Re: Andy Z]
Andy Z Online

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Registered: 10/27/00
Posts: 25295
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Military OneSource does confirm the number on their website. The lady I spoke with was not aware of the overseas number, but I did find this in their FAQ section.

Q: How do I find out more?

A: Call Military OneSource at 1-800-342-9647 (CONUS), or 800-3429-6477 or 484-530-5908 (OCONUS). For more information on calling Military OneSource from overseas visit www.militaryonesource.com and click on “Contact Us.” A consultant can give you more information about online consultations and discuss your options with you.
_________________________
AndyZ CRCM
My opinions are not necessarily my employers.
R+R-R=R+R
Rules and Regs minus Relationships equals Resentment and Rebellion. John Maxwell

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#1510636 - 02/16/11 09:27 AM Re: Servicemember notice - correct language. [Re: Andy Z]
JoeCompliance
Unregistered


Anyone going overseas anytime soon? 50/50 chance at getting a "friendly" person on the line.

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#1514242 - 02/24/11 01:30 PM Re: Servicemember notice - correct language. [Re: ]
RR Joker Offline
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so, do we or don't we need the extra number?? Honestly, it looks like a typo from the 9647 to 6477.
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#1515124 - 02/25/11 06:16 PM Re: Servicemember notice - correct language. [Re: RR Joker]
Andy Z Online

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My own opinion is I would add the additional number. Using a belt and suspenders risk managment attitude, that isn't a significant variance and is meaningful as to reaching a good number. The company that does the counselling has that number on their site and has said it was a good number.

HUD has my request for verification. But I won't hold my breath on waiting for an answer. These things take time. Factor in that regulators are aware of this, and I don't see them citing banks for the variance.
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#1521396 - 03/14/11 02:24 PM Re: Servicemember notice - correct language. [Re: Andy Z]
Reads Regs Offline
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HUD posted an updated SCRA notice. They corrected the phone number to dial when calling from outside the U.S.

http://www.hud.gov/offices/adm/hudclips/forms/files/92070.doc
http://www.hud.gov/offices/adm/hudclips/forms/files/92070.pdf
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#1521452 - 03/14/11 03:44 PM Re: Servicemember notice - correct language. [Re: Reads Regs]
JoeCompliance
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Too bad there is not a way for banks to cite HUD with a violation and somehow force extend comment periods or just delay the effective date for new actions.

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#1521712 - 03/15/11 09:39 AM Re: Servicemember notice - correct language. [Re: ]
goingtoexperts Offline
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Looking at the latest version, it appears the first bullet under the "What Legal Protections" was also revised?

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#1523011 - 03/17/11 10:27 AM Re: Servicemember notice - correct language. [Re: goingtoexperts]
Andy Z Online

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I am updating our notice now. It will be available for download in just a minute.

These changes were made because of JoeCompliance and BOL contacting HUD. Now the info is correct!

http://www.bankersonline.com/tools/lender/hud_scra.html




Edited by Andy Z (03/17/11 10:27 AM)
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#1523692 - 03/18/11 09:01 AM Re: Servicemember notice - correct language. [Re: Andy Z]
beachbum Offline
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Going back to a previous question asked. Does this only apply to a consumer closed-end loan secured by the primary residence including Home Equity Loans? Should the notice be given in the instance of a business loan secured by a guarantor's primary residence, or for a business loan secured by a residence to be used for investment purposes? The information just states residential mortgage.
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#1523940 - 03/18/11 01:00 PM Re: Servicemember notice - correct language. [Re: beachbum]
Andy Z Online

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I would say that it does apply, when that borrower could now be protected under the SCRA.
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#1523948 - 03/18/11 01:03 PM Re: Servicemember notice - correct language. [Re: Andy Z]
Andy Z Online

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The HUD form now just refers to the Military OneSource website and does not have the (wrong-looking) international number. I'd swear it was there yesterday and was stated to me that it was as well, from HUD.

I'm thinking it was changed again.
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#1523978 - 03/18/11 01:33 PM Re: Servicemember notice - correct language. [Re: burgess]
palmertown Online
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Does anyone know if HUD issued any kind of press release informing banks that the notice was updated?

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#1524046 - 03/18/11 02:20 PM Re: Servicemember notice - correct language. [Re: palmertown]
Andy Z Online

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They didn't issue a notice when it was updated in January. It shows on the HUD Clips as be a new item.

http://portal.hud.gov/hudportal/HUD?src=/program_offices/administration/hudclips/whatsnew

I've updated the BOL form to match the one HUD has there now. That is, the international number has been removed and the SM is referred to the OneSource website. Lets hope all the soldiers who get mail have an internet connection.
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#1526004 - 03/23/11 02:45 PM Re: Servicemember notice - correct language. [Re: Andy Z]
mtngrrl, crcm Online
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Just when you thought it was safe--and I sent out corrected language yesterday--they changed it once again today. Now the bullet reiterates the url for military onesource, instead of just referring to "the above website".

Think they're done tweaking yet? At least it now has a March version date!

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#1526033 - 03/23/11 03:00 PM Re: Servicemember notice - correct language. [Re: mtngrrl, crcm]
Reads Regs Offline
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Thanks!!! Typical from HUD.
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#1526182 - 03/23/11 06:05 PM Re: Servicemember notice - correct language. [Re: Reads Regs]
SMQ, CRCM Offline

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Of course, it's the government, we have to handle everything they do at least 3 times.
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#1526263 - 03/24/11 09:11 AM Re: Servicemember notice - correct language. [Re: SMQ, CRCM]
Sinatra Fan Online
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Thanks, everyone, for keeping us updated on this! BOL is absolutely your best friend when it comes to compliance and keeping on top of the myriad of mind-numbing regulatory changes.

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#1527906 - 03/28/11 06:43 PM Re: Servicemember notice - correct language. [Re: Sinatra Fan]
Andy Z Online

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FWIW I have updated our page. I'm not sure if this is an exercise in futility though since they also make it available now in Word form. Originally it was just a PDF.
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#1528000 - 03/29/11 09:11 AM Re: Servicemember notice - correct language. [Re: Andy Z]
markp Offline
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Thanks for all the great information on this topic. I cut out any confusion, who and when are we required to send this disclosure to?

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#1528084 - 03/29/11 10:03 AM Re: Servicemember notice - correct language. [Re: markp]
SMQ, CRCM Offline

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We combined this notice with the counseling notice that goes out to anyone that is 30 days past due. Since our system automatically generates a past due notice at 30 days (the SSCRA notice is required by 45 days) it was easiest and more cost effective to just include with a notice that was already going out.
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#1529511 - 03/31/11 11:51 AM Re: Servicemember notice - correct language. [Re: SMQ, CRCM]
mtngrrl, crcm Online
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Checking the HUD website again today just to confirm it's not still a moving target--the link on HUD Clips is now dead, and the only other place I could find the form on the HUD website still has the OLD version. Wonder if that means they're working on changing it yet again...
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#1529906 - 03/31/11 04:06 PM Re: Servicemember notice - correct language. [Re: mtngrrl, crcm]
Andy Z Online

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I got a call from a banker today who called HUD because he too was checking for updates. A HUD rep told him the forms were pulled pending review of the text by the DoD.

What does that mean? It means you are required to send a notice, but no one currently will say what that notice should say.

My best estimate at this time is to send what was last available. Your other option is to send nothing, and you know that won't work. The choice is obviously yours. The whole thing has been frustrating.
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#1531887 - 04/06/11 07:52 AM Re: Servicemember notice - correct language. [Re: Andy Z]
rockchalk02 Offline
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#1531922 - 04/06/11 09:15 AM Re: Servicemember notice - correct language. [Re: rockchalk02]
upstateNY Offline
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Do we dare use this one now????

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#1531958 - 04/06/11 09:58 AM Re: Servicemember notice - correct language. [Re: upstateNY]
Reads Regs Offline
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Did you notice that the PDF version has a revision date of 1/11 in the lower right hand corner and that the Word document has a 3/11 date?
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#1532318 - 04/06/11 02:38 PM Re: Servicemember notice - correct language. [Re: Reads Regs]
bike4life Offline
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Make sure you are sending the notice to all borrowers with loans secured by any 1-4 residential home - regardless of loan purpose and lien position. We were not sending these to our commercial borrowers and were cited by our FDIC examiner because HUD does not exclude business-purpose loans from the notice requirement. For example, a servicemember could have a home in PA but be stationed in Georgia. Many time the servicemember will rent out their residence in their home state and buy another home near their duty station. If the home in PA is secured by a mortgage, the servicemember's rights under the SCRA are to be apply to the house in PA they are renting out as well. Our commercial loan delinquency notices are handled by a different department than our residential loans, so we were not complying with the notice requirement on the commercial side.

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#1532637 - 04/07/11 08:21 AM Re: Servicemember notice - correct language. [Re: bike4life]
MarieR Offline
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The two forms are different. The pdf has the phone number and the word doc has the website. Are they really ever going to get this right?
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#1533611 - 04/08/11 04:55 PM Re: Servicemember notice - correct language. [Re: MarieR]
Andy Z Online

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I'm not seeing the form on HUD Clips?

HUD-92068-A Monthly Delinquent Loan Report (10/2006))
HUD-92080 Mortgage Record Change--Multifamily (10/05)
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#1533823 - 04/11/11 10:45 AM Re: Servicemember notice - correct language. [Re: Andy Z]
Phoenix Offline
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same as of this AM. Andy, is it possible that someone at HUD read this thread and realized that the DOC and PDF versions aren't in sync?

; )
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#1534094 - 04/11/11 05:49 PM Re: Servicemember notice - correct language. [Re: Phoenix]
Reads Regs Offline
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This page on HUD's website has a link to a PDF version of the notice but it is the one dated 1/11. http://portal.hud.gov/hudportal/HUD?src=/program_offices/housing/sfh/nsc/qasscra1
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#1534262 - 04/12/11 10:15 AM Re: Servicemember notice - correct language. [Re: Reads Regs]
Phoenix Offline
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what about (found yesterday, after a lot of digging)
http://portal.hud.gov/hudportal/documents/huddoc?id=DOC_35467.doc

or is that out of date, too?
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#1534769 - 04/13/11 08:55 AM Re: Servicemember notice - correct language. [Re: Phoenix]
Sinatra Fan Online
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What a joke. HUD can't even post a simple one-page form correctly on their web site, and yet they now require regulated, examined institutions to submit a detailed audit report annually to them.

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#1534835 - 04/13/11 10:19 AM Re: Servicemember notice - correct language. [Re: Sinatra Fan]
Phoenix Offline
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while you can get to that Word version via the hyperlink, you can not find it if you simply use the search box on hud.gov. Unbelievable.

and, although the Federal Government really pushes www.militaryonesource.com as the single best reference to answer all types of non-combat questions and concerns, it's tough to find a quick, short link to its information on SCRA. : (
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#1535682 - 04/14/11 01:11 PM Re: Servicemember notice - correct language. [Re: Phoenix]
JacksTigger Online
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I know that the HUD SCRA notice is for residential loans.

I've searched and searched, but can't find this.... cry

Is there a required notice that must go out to delinquent borrowers on other consumer purpose loans, like auto loans??
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#1536021 - 04/15/11 10:16 AM Re: Servicemember notice - correct language. [Re: JacksTigger]
Andy Z Online

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I've seen no requirement or suggestions for other loans.
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#1536119 - 04/15/11 11:47 AM Re: Servicemember notice - correct language. [Re: Andy Z]
JacksTigger Online
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Ok - so it's not required.

Would it be wrong to include a short statement about calling us if you are on active duty on letters to delinquent borrowers for other loans?? confused

We have a affiliate that only has other consumer purpose loans, cars, boats, RV's. Trying to figure out if a statment should/could be on their letters too.

Thoughts???
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#1537623 - 04/19/11 03:26 PM Re: Servicemember notice - correct language. [Re: JacksTigger]
Phoenix Offline
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[PDF] Servicemembers Civil US Department of Housing Relief Act and Urban ... ... Legal Rights and Protections Under the SCRA Servicemembers ... App. §§ 501-596) (SCRA).
Who May Be Entitled to Legal Protections Under the SCRA? ...
portal.hud.gov/idc/groups/chco_admingrp/documents/document/doc_13065.pdf.pdf - 2011-04-03 - Text Version


so - is this the latest, correct link to HUD 92070?
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#1538008 - 04/20/11 12:13 PM Re: Servicemember notice - correct language. [Re: Phoenix]
Andy Z Online

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Honestly since they posted, revised and pulled, I don't know what HUD would say is the latest. By the date, that wouldn't have been. I don't believe they know at this point.

Jacks, I don't know if MilitaryOnesource would answer questions or assist on non-mortgage debt, if they'd impose a fee or what. I assume (yes, I live dangerously) that OnsSource is a contractor and bills DoD for the records they submit.
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#1550041 - 05/12/11 10:57 AM Re: Servicemember notice - correct language. [Re: Reads Regs]
Ann Offline
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Apparently it has disappeared again. Does anyone know what is going on and which version we should be using?

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#1550648 - 05/12/11 07:00 PM Re: Servicemember notice - correct language. [Re: Ann]
Andy Z Online

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There is no good answer. Personally because you are required to provide a notice, and do not suspect any major errors were evident, I would use the latest we had. I think it is better than nothing. Obviously on the other side of the coin it was pulled for a reason. But at least the notice of free counselling is being sent this way.

As to an official version, currently there isn't one. Whether that is a good reason not to send it as required is any one's call. :p

The shame of it is that it is required and presumably has a purpose, but the message that HUD is sending is that it is of no importance.
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#1551021 - 05/13/11 01:18 PM Re: Servicemember notice - correct language. [Re: Andy Z]
bike4life Offline
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And I'm sure the person that HUD listed to contact for questions will be extremely pleasant and helpful....

HUD-92070 Servicemembers Civil Relief Act Notice Disclosure
(This particular form is temporarily unavailable at this time. If you have any questions regarding this form, please contact Camille Acevedo at (202) 708-1793 x5132 per the program office contact.)

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#1566214 - 06/16/11 06:29 PM Re: Servicemember notice - correct language. [Re: bike4life]
Andy Z Online

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HUD has updated the form. I've updated the BOL tool and have a PDF version denoting the differences between the March and June versions. They are signficant. On our Word verion, I corrected a HUD typo.

http://www.bankersonline.com/tools/tools.html
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#1566296 - 06/17/11 08:41 AM Re: Servicemember notice - correct language. [Re: Andy Z]
Sinatra Fan Online
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Thanks, Andy! As nuts as it is trying to keep up with the various iterations of the HUD notice, I can't imagine doing it without BOL's help!!!

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#1566332 - 06/17/11 09:20 AM Re: Servicemember notice - correct language. [Re: Sinatra Fan]
Dave M_TCA Online
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Nut's is right Sinatra Fan. Not that I doubt BOL (never!) but I haven't found the revised form on HUDs website. Anyone found it there yet?
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#1566333 - 06/17/11 09:29 AM Re: Servicemember notice - correct language. [Re: Sinatra Fan]
Always In Training Offline
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RAnt- Our core provider fixed YESTERDAY the previous change. ARGH! End Rant.

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#1566394 - 06/17/11 10:15 AM Re: Servicemember notice - correct language. [Re: Always In Training]
John Burnett Offline
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There's one other typo in the Word document downloaded from the HUD site. The last paragraph refers to the "Unites States." We're making that change to the BOL Tools version of the document.

"DUH" strikes again.
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#1566399 - 06/17/11 10:15 AM Re: Servicemember notice - correct language. [Re: Dave M_TCA]
Andy Z Online

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Originally Posted By: Jacob's Dad
Nut's is right Sinatra Fan. Not that I doubt BOL (never!) but I haven't found the revised form on HUDs website. Anyone found it there yet?


Another poster gave us http://portal.hud.gov/hudportal/documents/huddoc?id=92070.doc but it has a couple typos.
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#1566402 - 06/17/11 10:18 AM Re: Servicemember notice - correct language. [Re: Andy Z]
Phoenix Offline
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You won't find it if you just search on "SCRA" on the HUD website. Andy's link is best, but - duh.
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#1566427 - 06/17/11 10:46 AM Re: Servicemember notice - correct language. [Re: Phoenix]
Dave M_TCA Online
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Thanks guys. It's too bad that HUD doesn't have spell-check on their computers.
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#1566951 - 06/20/11 11:24 AM Re: Servicemember notice - correct language. [Re: Always In Training]
sewanee, CRCM Online
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Any idea how long we have to start using the new one?
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#1567487 - 06/21/11 10:58 AM Re: Servicemember notice - correct language. [Re: sewanee, CRCM]
Carolina Blue Online
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I'm trying to find out as well. Not that it really matters since most likely they will change it again a few weeks after we adopt these changes. tired

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#1567953 - 06/21/11 06:48 PM Re: Servicemember notice - correct language. [Re: Carolina Blue]
Andy Z Online

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The requirement hasn't changed. HUD simply isn't and hasn't made the notice available because there were discussions between HUD and DoD(?) as to what the notice should say. I would start using it ASAPractical.
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