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#1565784 - 06/16/11 03:34 PM SCRA Notice - June revision???
Tarhe Offline
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Our vendor is saying that there has been a June 2011 revision to the model language for HUD's SCRA Notice?? Has something changed??

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Lending to Servicemembers (SCRA, JWNDAA), War, Terrorism
#1565812 - 06/16/11 04:00 PM Re: SCRA Notice - June revision??? Tarhe
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#1565998 - 06/16/11 06:40 PM Re: SCRA Notice - June revision??? Loynograd
mtngrrl Offline
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And once again with no notice. I don't know how you even managed to find that link! I've been searching the HUD site for any kind of announcement (not that I expect it) or even a link to the url listed by loynograd, and I find nothing. After the fiasco early in the year I'm hesitant to take any action for...oh say...six weeks or so?
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#1566213 - 06/16/11 10:27 PM Re: SCRA Notice - June revision??? mtngrrl
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I've updated the BOL tool and have a PDF version denoting the differences. They are signficant. On the Word verion, I corrected a HUD typo.

http://www.bankersonline.com/tools/tools.html
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#1566379 - 06/17/11 02:05 PM Re: SCRA Notice - June revision??? Andy_Z
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.
Last edited by John Burnett; 06/17/11 02:13 PM.
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#1566716 - 06/17/11 08:20 PM Re: SCRA Notice - June revision??? John Burnett
Sewanee, CRCM Offline
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Does anyone have an opinion as to how long we have to get the June revision into use?
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#1566980 - 06/20/11 03:48 PM Re: SCRA Notice - June revision??? Sewanee, CRCM
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I am a little confused. it sounds like it's up to us to monitor our entire portfolio to determine whether or not we've made any real-estate secured loans to military...

ē There is no requirement under the SCRA, however, for a servicemember to provide a written notice or a copy of a servicememberís military orders to the lender in connection with a foreclosure or other debt enforcement action against real estate. Under these circumstances, lenders should inquire about the military status of a person by searching the Department of Defenseís Defense Manpower Data Centerís website, contacting the servicemember, and examining their files for indicia of military service. Although there is no requirement for servicemembers to alert the lender of their military status in these situations, it still is a good idea for the servicemember to do so."

I can't even imagine trying to do that?

What is everyone else doing?

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#1567261 - 06/20/11 08:47 PM Re: SCRA Notice - June revision??? Many Hats
Tesla Offline
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This applies if the bank is taking collection efforts. In those cases, your loss mitigation people would just look up the names of your borrowers on the DOD's website or check their deposit history for military deposits or file for military information (does the loan app show part time pay from being a reservist?)and there you go. Check with your collections people - and make sure they have the right tools to do this.

HTH! smile
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#1567404 - 06/21/11 01:22 PM Re: SCRA Notice - June revision??? Tesla
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Our collections people are our loan officers and I am sure they aren't even thinking of this.

We do send the SCRA notice to all 30-day past due customers. But, it sounds like that is not sufficient.

Let's say we do have a customer that shows part time pay on the application as a reservist, for example, and they become delinquent on their RE mortgage. Do we have to reduce their rate?

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#1567954 - 06/21/11 10:57 PM Re: SCRA Notice - June revision??? Many Hats
Andy_Z Offline
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I would start using the new notice ASAPractical. Since its existence isn't well known, I'd hate to think you'd be dunned for not sending what you weren't told to send.

This should go to all applicable mortgages. The deal is, you can't know the current status of all your borrowers. So you send this by 45 days.

Rate reductions are done upon request. There are plenty of threads explaining the process.
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#1568600 - 06/23/11 12:11 PM Re: SCRA Notice - June revision??? Andy_Z
donna.raisor Offline
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This notice is to be sent to only loans that are people in the military and they are past due and real estate, correct?

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#1569643 - 06/24/11 04:37 PM Re: SCRA Notice - June revision??? donna.raisor
Khaleesi Offline
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Donna-
Per the HUD website in regaurds to the SCRA notice:

Be sent to all homeowners who are in default on a residential mortgage;
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#1569844 - 06/24/11 07:38 PM Re: SCRA Notice - June revision??? Khaleesi
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Because, Donna, you don't know whether a mortgagor is in the military.
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#1569845 - 06/24/11 07:39 PM Re: SCRA Notice - June revision??? Khaleesi
John Burnett Offline
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Because, Donna, you don't know whether a mortgagor is in the military.
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#1573192 - 07/01/11 06:08 PM Re: SCRA Notice - June revision??? John Burnett
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#1573277 - 07/01/11 07:22 PM Re: SCRA Notice - June revision??? mtngrrl
Andy_Z Offline
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John had that in our Compliance Briefing this morning. And when I reviewed their form it still has the same two typos.
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#1575023 - 07/07/11 04:31 PM Re: SCRA Notice - June revision??? Andy_Z
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According to the HUD requirement that the notice "Be sent to all homeowners who are in default on a residential mortgage"

-Loans that are classified as ag or commercial, but a primary residence or even a residence (hired hand) is on the property.
-Construction loans
-Manufactured housing loans that are not traditional mortgages.

How do these fit into the mix?
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#1575373 - 07/08/11 07:24 AM Re: SCRA Notice - June revision??? GenerousLife
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How you classify them is moot. Review the HUD ML for the crystal clear guidance they provide (I crack myself up).

But they do say:
"Be sent to all homeowners who are in default on a residential mortgage"
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#1575432 - 07/08/11 01:24 PM Re: SCRA Notice - June revision??? Andy_Z
GenerousLife Offline
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You DO crack me up! When I said the exact same thing during our panic-mode meeting, no one else laughed either.

Thank goodness for BOL, at least there is one place where our humor is appreciated!
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#1575496 - 07/08/11 02:58 PM Re: SCRA Notice - June revision??? GenerousLife
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I sent a listing of the commercial loans that had residential property listed as collateral to the loan officers and had them provide the names and addresses of owners so that we had a name and address to send the HUD-SCRA notice in case the commercial loans were past due.

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#1575731 - 07/08/11 06:33 PM Re: SCRA Notice - June revision??? John Burnett
Raquel Offline
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Isn't there another HUD typo in the form? Under the "Who May Entitled..." heading, in the listing of branches of the Armed Forces, shouldn't there be a comma between Force and Marine?

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#1575808 - 07/08/11 08:04 PM Re: SCRA Notice - June revision??? Raquel
John Burnett Offline
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You are correct, Raquel. I'll get our copy of the form updated.

Why do I feel like BOL's version is like putting rouge on a pig?
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#1575821 - 07/08/11 08:18 PM Re: SCRA Notice - June revision??? John Burnett
Andy_Z Offline
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Comma added to the Word file. Thx.
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#1575947 - 07/09/11 04:06 PM Re: SCRA Notice - June revision??? Andy_Z
rlcarey Online
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The latest copy on the HUD website now has the corrections - except the comma.....
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#1575969 - 07/09/11 08:18 PM Re: SCRA Notice - June revision??? rlcarey
John Burnett Offline
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Getting them up to speed is like pulling teeth!
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#1576765 - 07/12/11 04:26 PM Re: SCRA Notice - June revision??? Andy_Z
cle Offline
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Does this notice need to be provided each time the customer is in default or once you have provided the notice you are done?

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#1576778 - 07/12/11 04:38 PM Re: SCRA Notice - June revision??? cle
GenerousLife Offline
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Each time.
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#1576793 - 07/12/11 04:49 PM Re: SCRA Notice - June revision??? GenerousLife
cle Offline
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Thanks GenerousLife.

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#1582777 - 07/25/11 09:30 PM Re: SCRA Notice - June revision??? cle
raitchjay Online
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Is this notice only for loans insured by HUD (FHA loans and the like)?
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#1582934 - 07/26/11 02:32 PM Re: SCRA Notice - June revision??? raitchjay
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I ask because of this quote from Consumer Compliance Outlook: "It should also be noted that creditors originating mortgage loans insured by the U.S. Department of Housing and Urban Development (HUD), such as Federal Housing Adminisitration loans, must provide a notice to borrowers who default on these loans, informing them of the rights available to service members under the SCRA." So, the notice only goes out for FHA loans?
Last edited by raitchjay; 07/26/11 02:33 PM. Reason: typo
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#1583270 - 07/26/11 06:55 PM Re: SCRA Notice - June revision??? raitchjay
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See Dan's post in this prior thread .
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#1583303 - 07/26/11 07:21 PM Re: SCRA Notice - June revision??? Reads Regs
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Thanks RR. Curious wording in the compliance piece i was reading then.
Last edited by raitchjay; 07/26/11 07:22 PM.
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