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#1957174 - 08/26/14 09:12 PM New Executive Actions today - SCRA?
QCL Offline
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QCL
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NW IL
http://www.whitehouse.gov/the-press-offi...s-fulfill-our-p

Today the White House announced a new Servicemembers Civil Relief Act (SCRA) initiative. This initiative was created so service members can maximize all of the protections under SCRA, including the six percent interest rate cap.

From the Orders:
Ensuring All Service Members Have Every Opportunity to Pursue the American Dream

President Obama will announce a new voluntary partnership with financial lenders across the country that will help deliver important financial and home loan-related protections to our military community. Congress passed the Service members Civil Relief Act (SCRA) in 2003 to provide protections for military members as they enter active duty. Our Service women and men have earned important financial protections under the law, but too many do not exercise these important rights. But when business and government work together we can make a difference.

Banks and Mortgage Servicers Answer the President’s Call to Action: Wells Fargo Bank, N.A., CitiMortgage, Inc., Bank of America, N.A., Ocwen Loan Servicing, LLC, and Quicken Loans are partnering with the Administration to make it easier than ever for active duty service members to obtain mortgage interest rate reductions and reduce their monthly payments. The partnership cuts red tape where possible and establishes concrete steps to reduce the burden on service members by having participating mortgage servicers proactively identify, notify and assist in enrolling eligible service members.

Key Provisions of the Partnership
•Proactive Identification of Active Duty Service Members: Under the partnership, participating servicers will proactively identify active duty personnel no less than once a quarter by querying the Defense Manpower Data Center (DMDC), a searchable database of individuals who were or on Title 10 active duty status, against their loan portfolio, reducing the burden on the service member.
•Proactive Outreach to Eligible Service Members: Participating mortgage servicers will proactively reach out to individuals that have been identified as being eligible for benefits under SCRA to notify them of their benefits. Servicers will leverage multiple marketing and communication tactics including telephone, mail, e-mail, or other reasonable forms of communication.
•Simplify the Application Process: Participating mortgage servicers will work together to ease the burden of enrollment and satisfaction of the SCRA written notice requirement.


In our shop, we sell loans to Freddie Mac, we just got an email from them and they are encouraging banks to participate.
We are asked to:
•Search the online Defense Manpower Database Center (DMDC) on a quarterly basis to find service members in their portfolio that have Note Rates greater than six percent.
•Offer interest rate relief for eligible, active service members.
•Use the DMDC to confirm a borrower's military status instead of requiring the service member to provide a copy of their orders.

Thoughts?


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Lending to Servicemembers (SCRA, JWNDAA), War, Terrorism
#1957365 - 08/27/14 03:47 PM Re: New Executive Actions today - SCRA? QCL
AngelMae CRCM Offline
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Indiana
I would be interested in any thoughts as well. The DMDC is a very manual process and searching it on a quarterly basis is a huge undertaking!

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#1957382 - 08/27/14 04:17 PM Re: New Executive Actions today - SCRA? QCL
JWills, CRCM Offline
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I received the Freddie Mac update yesterday as well.

I went to the link to the DMDC, got a certificate error, and sent message to my IT.

We have never used the DMDC to my knowledge.
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#1957384 - 08/27/14 04:18 PM Re: New Executive Actions today - SCRA? QCL
Kathleen O. Blanchard Offline

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The DMDC process can be automated, searching in batches.
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#1957395 - 08/27/14 04:34 PM Re: New Executive Actions today - SCRA? JWills, CRCM
QCL Offline
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QCL
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NW IL
Originally Posted By: JWills
I received the Freddie Mac update yesterday as well.

I went to the link to the DMDC, got a certificate error, and sent message to my IT.

We have never used the DMDC to my knowledge.


The gave us the old link.
Here is the correct one:
https://www.dmdc.osd.mil/appj/scra/help.do

They gave us:
https://www.dmdc.osd.mil/appj/dwp/ (which still has a certificate issue)

We use this already to search for borrowers before sending a loan to foreclosure.

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#1957396 - 08/27/14 04:35 PM Re: New Executive Actions today - SCRA? QCL
JWills, CRCM Offline
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The Mitten State
Thanks QCL!
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#1957410 - 08/27/14 04:48 PM Re: New Executive Actions today - SCRA? QCL
QCL Offline
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QCL
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NW IL
I just created my account for a batch upload like Kathleen said.
I could not create it on firefox - had to use Internet explorer (the captcha verification would not show up on firefox, strange).

https://www.dmdc.osd.mil/appj/scra/welcome.xhtml

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#1957862 - 08/28/14 04:59 PM Re: New Executive Actions today - SCRA? QCL
Andy_Z Offline
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I haven't looked at all the info released yet, but I am under the impression that the major mortgage lenders are taking the hint and being proactive on SCRA rights like some of those subject to enforcement actions are. An example is that they'll run their servicing database against the DMDC and will take any hit and place that account on its list of SCRA accounts. The SM need not contact or provide orders to the lender. They're using the database as gospel. That is the key takeaway I see. It goes above and beyond requiring orders and a request for protection.

In the past the DMDC database was to check on a status before collection/legal/foreclosure actions were taken. Now it is eligibility in the first place.
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#1959201 - 09/04/14 02:11 PM Re: New Executive Actions today - SCRA? Andy_Z
Raquel Offline
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Does anyone have any idea as to how reliable this database is? It was my understanding that not all occupations were included that were entitled to SCRA protections such as National Guard, reserves, Public Health, and some officer postions. One search that was done did not list the servicemember at all; however, there was military pay being deposited to his checking account.

The person who handles the rate reductions was wanting to know if the database could be used to determine whether the reduction should continue. Am hesitant to use for this purpose and the only "official" suggestions for use seem to be to determine eligibility and not to determine that someone is no longer eligible.

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#1959547 - 09/05/14 12:28 PM Re: New Executive Actions today - SCRA? QCL
Kathleen O. Blanchard Offline

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I would not use it for "negative actions" without further due diligence whether it lists all occupations or not. There is too much at risk for the bank to harm a consumer who is entitled to protections. Use it as a reason to obtain more information before taking a negative action against the consumer.
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Kathleen O. Blanchard, CRCM "Kaybee"
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#1959553 - 09/05/14 12:56 PM Re: New Executive Actions today - SCRA? Kathleen O. Blanchard
BankerMike Offline
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Regarding this --- we've been researching a way to go about this for our bank. Wanted to know if others are doing this and if so how, (i.e. in-house, in-house with IT help to pull data together, or outside vendors)?

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#1959896 - 09/05/14 09:45 PM Re: New Executive Actions today - SCRA? QCL
Andy_Z Offline
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My basic understanding is this is DoD input which is the majority of your requests. NOAA and others could use the traditional requests so I wouldn't narrow SCRA protections to ONLY those on a DoD database.
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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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#1960234 - 09/08/14 09:59 PM Re: New Executive Actions today - SCRA? QCL
DoorKey Offline
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My reading of the announcement is that this is VOLUNTARY and not a new requirement. I agree that proactively comparing the bank's database to the DOD site is good thing to do. However, until there is an interface that we could use to search the DOD site automatically and not on a one-by-one basis, I do not recommend that our bank partake in this endeavor.
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#1960240 - 09/08/14 10:42 PM Re: New Executive Actions today - SCRA? QCL
Kathleen O. Blanchard Offline

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Whether you do or not is up to you, but did you read above about the ability to run quite large batches through the database? There is no need to search one by one.
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Kathleen O. Blanchard, CRCM "Kaybee"
HMDA/CRA Training/Consulting/Mapping
The HMDA Academy
www.kaybeescomplianceinsights.com

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