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#1968289 - 10/09/14 01:29 PM SCRA Notice - expires 11/30/14?
LuckySoFar Offline
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Hopefully this is not a stupid question....the current disclosure (HUD-92070) has an 11/30 expiration date. Will a new form be available soon?
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Lending to Servicemembers (SCRA, JWNDAA), War, Terrorism
#1970391 - 10/17/14 09:41 PM Re: SCRA Notice - expires 11/30/14? LuckySoFar
Andy_Z Offline
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There was a history here of expired forms, numerous changes to correct errors, etc. I wouldn't hold my breath though with the CFPBs military section it MIGHT be addressed. In the meantime I'd continue to use what is published now.
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#1979784 - 11/28/14 09:29 PM Re: SCRA Notice - expires 11/30/14? Andy_Z
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I just checked the HUD web site, and the only form 92070 they are showing is the current form.

Just love the way lenders MUST comply with dates, but the government gets a free pass.
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#1979810 - 11/30/14 05:47 AM Re: SCRA Notice - expires 11/30/14? LuckySoFar
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Not surprising.
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#1980054 - 12/01/14 09:21 PM Re: SCRA Notice - expires 11/30/14? LuckySoFar
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The ABA said they are trying to get a answer from HUD - this mornings ABA newsletter.

The ABA says there shouldn't be a problem using the current expired form in December because the info is still accurate. the problem is on January 1st when the section that requires court orders before a bank can take action on a default goes from one year after the borrower gets out of active duty to 90 days after active duty.
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#1980138 - 12/01/14 11:51 PM Re: SCRA Notice - expires 11/30/14? LuckySoFar
Andy_Z Offline
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Either that will be extended and the form use can continue, or the content of the form would require a change as it will otherwise be inaccurate. It isn't all under HUD's control but that is of little comfort. Since the biggest risk of noncompliance penalties comes from regulatory agencies perhaps guidance will come from there, including the Servicemember Affairs area at the CFPB.
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#1980140 - 12/02/14 12:11 AM Re: SCRA Notice - expires 11/30/14? LuckySoFar
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#1982963 - 12/14/14 01:55 AM Re: SCRA Notice - expires 11/30/14? LuckySoFar
Andy_Z Offline
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I believe with the extension the current form will be correct for another year.
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#1982964 - 12/14/14 01:56 AM Re: SCRA Notice - expires 11/30/14? LuckySoFar
Andy_Z Offline
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http://www.providencejournal.com/politic...-whitehouse.ece

I mentioned in another post it appears to be a done deal.
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#1985848 - 12/31/14 06:16 PM Re: SCRA Notice - expires 11/30/14? LuckySoFar
Val Jo Offline
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Now it appears HUD has a new form (Exp 12/31/17) but it only speaks to the 90 day time period for legal action although the one year time frame has been extended until Dec 31, 2015. Oh, brother.

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#1985987 - 01/02/15 03:20 PM Re: SCRA Notice - expires 11/30/14? LuckySoFar
John Burnett Offline
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I suggest you continue to use the older form until HUD wakes up to the fact that the sunset date was extended for another year.
Last edited by John Burnett; 01/02/15 08:29 PM.
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#1986563 - 01/06/15 05:53 PM Re: SCRA Notice - expires 11/30/14? LuckySoFar
Andy_Z Offline
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FWIW I hope to get a Word version up in the Tools section and will link to it. But in common HUD SOP, they posted a new notice (form 92070) BUT the new HUD version reverted to 90 days of protection while the new law extended the 1 year protection time. So I expect they'll make yet another change and we will preempt that with the legally require time as a BOL correction.
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#1986652 - 01/06/15 08:37 PM Re: SCRA Notice - expires 11/30/14? LuckySoFar
John Burnett Offline
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Andy did get both the Word and PDF versions of the HUD SCRA Notice Disclosure (Form 92070) updated on our Banker Tools page at http://www.bankersonline.com/tools/lender/hud_scra.html

I'll note the update in tomorrow's Compliance Briefing, too.
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#1987001 - 01/07/15 07:01 PM Re: SCRA Notice - expires 11/30/14? LuckySoFar
RebekahL CRCM Offline
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So, should we:

- Use HUD's official 12/31/17 form as-is, with the inaccurate 90 day reference, knowing it is wrong, or
- Change "90 days" to "one year" because we know better than HUD, or
- Continue to use the old, expired, but accurate one?
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#1987010 - 01/07/15 07:06 PM Re: SCRA Notice - expires 11/30/14? LuckySoFar
RebekahL CRCM Offline
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I see in the answer to my questions referenced in the BOL Daily Briefing, but I cannot locate Andy's corrected version (.pdf or Word) here.
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#1987011 - 01/07/15 07:07 PM Re: SCRA Notice - expires 11/30/14? LuckySoFar
John Burnett Offline
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Of the three choices, I would use the fourth one, which is to pull down the WORD-formatted copy of the form from BOL's Banker Tools pages (http://www.bankersonline.com/tools/tools.html) insert your bank's name and any other needed "personalization," and save it as a PDF.

The HUD form (old one and new one) include a misspelling of "servicemender"

If you feel you must use a form from the HUD site, I recommend using the old one reflecting the one-year period. The new one provides false info.
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#1987012 - 01/07/15 07:07 PM Re: SCRA Notice - expires 11/30/14? LuckySoFar
RebekahL CRCM Offline
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Well, that's embarrasing. One need only scroll down.... blush
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#1987215 - 01/08/15 01:41 PM Re: SCRA Notice - expires 11/30/14? RebekahL CRCM
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(sigh) If only HUD--and other regulatory agencies--were as efficient as BOL.
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#1987399 - 01/08/15 07:27 PM Re: SCRA Notice - expires 11/30/14? LuckySoFar
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Amen!
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#1987464 - 01/08/15 09:58 PM Re: SCRA Notice - expires 11/30/14? LuckySoFar
John Burnett Offline
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HUD and the other regulatory agencies are all huge bureaucracies. BOL is not.
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#1987480 - 01/08/15 10:41 PM Re: SCRA Notice - expires 11/30/14? LuckySoFar
MariaV Offline
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Hi there,
first time poster, long time reader grin

I have a question on the new BOL version of SCRA Disclosure, is the 2017 expiration correct? the extension for the 1 year after service protection was only to 12/31/2015. I was thinking disclosure should also expire on 12/31/2015?


Appreciate your opinion on this.
Thanks

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#1987571 - 01/09/15 03:28 PM Re: SCRA Notice - expires 11/30/14? LuckySoFar
John Burnett Offline
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No. That's the expiration date for the form, and it's not necessarily connected to the expiration date of anything referred to in the form. Put another way, the notice itself will continue to be required after 12/31/15, although the "one-year" mention in two places could change to "90 days" after that date (unless Congress extends the date again).
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#1987776 - 01/09/15 10:31 PM Re: SCRA Notice - expires 11/30/14? LuckySoFar
MariaV Offline
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Oh okay, thanks for that info.

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#1987798 - 01/09/15 11:12 PM Re: SCRA Notice - expires 11/30/14? LuckySoFar
Andy_Z Offline
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I was confused as well, tying the changes to the law to the time to use the form. You'd think they'd want them to be in sync. But that's the user's perspective.
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#1987897 - 01/12/15 03:45 PM Re: SCRA Notice - expires 11/30/14? LuckySoFar
Julie Slack Offline
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Quick question for the group......when are you giving out the SCRA disclosure? I am not sure we are giving it to the borrower at the right time.

Just curious

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