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#1686463 - 04/06/12 02:26 PM SCRA Notice
Many Hats Offline
Platinum Poster
Joined: May 2008
Posts: 915
Orlando, FL
If we put this statement on our 30 day past due reminder notices (for consumer dwelling secured loans), would this be sufficient to comply with the SCRA notice requirements?

“The Servicemember Civil Rights Act (SCRA) protects all servicemembers and their dependents from undue hardship resulting from the service member not being able to meet their financial obligations due to being away on active duty in the military service. If you believe you may qualify, please see our website @ www.bank.com or contact our Compliance Officer @ ###-###-#### to receive a full copy of the Servicemember Civil Rights Act Notice Disclosure.”

Or, would you recommend sending the actual HUD notice itself?

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Lending to Servicemembers (SCRA, JWNDAA), War, Terrorism
#1686511 - 04/06/12 03:17 PM Re: SCRA Notice Many Hats
Dan Persfull Offline
10K Club
Dan Persfull
Joined: Aug 2002
Posts: 46,630
Bloomington, IN
The above would not be compliant. It's your responsibility to provide the notice, not the borrower's responsibility to contact you and ask for it.
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The opinions expressed are mine and they are not to be taken as legal advice.

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#1692923 - 04/26/12 05:06 PM Re: SCRA Notice Many Hats
ComplytillIdie Offline
100 Club
Joined: Feb 2012
Posts: 196
GA
I'm trying to audit the content of our SCRA Notice (HUD-92070)...where can I find exam procedures or the specifications for that form? Ii've checked FDIC HUD Exam Guide and SCRA Exam Guide and I don't see it in either.

I know a revised form was recently issued and I have that, but my forms vendor has only used one of the bullet points in the last section dealing contact information for obtaining legal assistance from the website. I have been unable to find guidance on what types of customization a lender can make to this notice.

Please advise.

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#1692932 - 04/26/12 05:11 PM Re: SCRA Notice Many Hats
rlcarey Offline
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rlcarey
Joined: Jul 2001
Posts: 78,597
Galveston, TX
http://portal.hud.gov/hudportal/documents/huddoc?id=92070.doc

It's an OMB form, I am not aware that it can be changed.
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The opinions expressed here should not be construed to be those of my employer: PPDocs.com

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#1692948 - 04/26/12 05:23 PM Re: SCRA Notice Many Hats
ComplytillIdie Offline
100 Club
Joined: Feb 2012
Posts: 196
GA
Great...I'll just give them the sample form and make them prove to me that it can be altered...

On to the next crisis...so many regulations, so little time. :-)

Thanks for the help!

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