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#1960954 - 09/10/14 07:42 PM Re: Servicemembers Civil Relief Act Notice Midwest123
3-2-Go Offline
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For Payday/car title loans, the disclosure that is required at application. How is everyone disclosing this? On application or separate notice?

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Lending to Servicemembers (SCRA, JWNDAA), War, Terrorism
#1961072 - 09/10/14 10:06 PM Re: Servicemembers Civil Relief Act Notice Tessie
rlcarey Offline
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Well, I don't think you are going to get many responses as most commercial banks don't make these sorts of loans.
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#1961862 - 09/13/14 07:42 PM Re: Servicemembers Civil Relief Act Notice Tessie
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If a bank was doing them, I would vote for a separate notice as it wouldn't be a typical product offered, IMHO.
Last edited by Andy Z; 05/05/17 09:30 PM.
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#2128307 - 04/27/17 08:10 PM Re: Servicemembers Civil Relief Act Notice Midwest123
Breeco Offline
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So it doesn't appear this question was answered? Any thoughts, as we are having the examiners tell us that it has to be sent out at 60/90/120 delinquency as well even though the HUD Handbook and the citation do not indicate that it has to be delivered more than once during any default event.

We also understand that if the loan becomes current and then past dueagain; it would need to be sent again. Everyone I talked to doesn't provide the notice more than once during a default event unless their system puts it on all past due notices [even non-mortgages] just because it's easier to do it that way.

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#2128324 - 04/27/17 09:41 PM Re: Servicemembers Civil Relief Act Notice Tessie
rlcarey Offline
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I think you are talking about a different notice,

However, show them 12 USC 1701x(c)(5). The notice is required to be delivered before the expiration of the 45-day period beginning on the date on which an eligible homeowner who fails to pay any amount by the date the amount is due under a home loan. Sending the notice again at 60/90/120 delinquency is long after the horse has left the barn.

Have them give you a citation or guidance document that says otherwise.
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#2129753 - 05/09/17 07:16 PM Re: Servicemembers Civil Relief Act Notice Tessie
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Nebraska
Thanks for responding Randy, I think I had to many windows open and posted on the wrong one.

Re: SCRA HUD-92070 Notice - We did reference the citation, but their internal consultants are not interpreting it that way.

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#2129756 - 05/09/17 07:28 PM Re: Servicemembers Civil Relief Act Notice Tessie
rlcarey Offline
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