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#2155872 - 12/04/17 04:01 PM SCRA HUD Form 92070 - Expiration End of 2017
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Has anyone seen anything regarding the extension of the SCRA HUD Form 92070? It's currently set to expire at the end of December 2017. I believe that the previous form, which expired at the end of December 2015, wasn't extended until January 2016. However, I'm hopeful an extension will occur earlier this time.

Thank you in advance for your feedback.

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#2155880 - 12/04/17 04:24 PM Re: SCRA HUD Form 92070 - Expiration End of 2017 ComplyCycle
rlcarey Offline
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Like all such things, it will probably be extended by Congress. Sending the notice is not going to hurt anything. I would not be changing any procedures. We face this sort of thing with these counseling notices every couple of years.
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#2156014 - 12/05/17 02:43 PM Re: SCRA HUD Form 92070 - Expiration End of 2017 ComplyCycle
StevenD Offline
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I'm not sure that the notice itself is expiring. What is expiring it the time-frame on the notice in the "What Legal Protections Are Servicemembers Entitled to Under the SCRA?" portion of the notice. It was expanded from nine months to one year for calendar year 2015, and then that was extended for two years to the end of this calendar year. The original time frame was "90 days" when the notice was introduced in 2007. With the expiration of "one year" will it revert to "nine months" or "90 days"?
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#2156015 - 12/05/17 02:45 PM Re: SCRA HUD Form 92070 - Expiration End of 2017 ComplyCycle
StevenD Offline
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I'm not sure that the notice itself is expiring. What is expiring it the time-frame on the notice in the "What Legal Protections Are Servicemembers Entitled to Under the SCRA?" portion of the notice. It was expanded from nine months to one year for calendar year 2015, and then that was extended for two years to the end of this calendar year. The original time frame was "90 days" when the notice was introduced in 2007. With the expiration of "one year" will it revert to "nine months" or "90 days"?
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#2156318 - 12/06/17 08:57 PM Re: SCRA HUD Form 92070 - Expiration End of 2017 ComplyCycle
StevenD Offline
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Based on what I see in PL 110-289, section 2203 and PL 112-154, section 710, if it expires, the time frame in the notice will go back to 90 days as it was before PL 110-289.
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#2156544 - 12/08/17 04:14 AM Re: SCRA HUD Form 92070 - Expiration End of 2017 StevenD
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See footnote 10 in the FDIC SCRA exam procedures. https://www.fdic.gov/regulations/compliance/manual/5/v-11.1.pdf

It mentions that the one year period will revert to 90 days after 12/31/17. We will have to see if Congress does anything to alter this.
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#2156623 - 12/08/17 06:13 PM Re: SCRA HUD Form 92070 - Expiration End of 2017 ComplyCycle
Andy_Z Offline
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The last time we hit this Congress waited until after the expiration, but just before foreclosures could start. The issue is the form will be incorrect, but likely will not be updated as they'll wait for the law (the 1 year provision to sunset) to be renewed. Does anyone think it will not be extended?

So from a HUD perspective why put out a new form on Monday saying 90 days with a new expiration and change it back to a year on Wednesday? My point in that example is we went thru that before. The fact is, the bank has to send the prescribed for. The prescribed form will be wrong. But how long do we expect the form to be wrong?

My recommendation is to continue on for now.
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#2156625 - 12/08/17 06:15 PM Re: SCRA HUD Form 92070 - Expiration End of 2017 ComplyCycle
Andy_Z Offline
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And this is on our BOL radar, we check it a couple times a week looking for updates but you never know where a provision will get attached. We'll keep you advised in the daily Compliance Briefing.
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#2156633 - 12/08/17 06:34 PM Re: SCRA HUD Form 92070 - Expiration End of 2017 ComplyCycle
rlcarey Offline
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It is sitting on the President's desk as part of H.R. 2810 as of 11/30/17.


Sec. 557. Temporary extension of extended period of protections for members of uniformed services relating to mortgages, mortgage foreclosure, and eviction.

Section 710(d) of the Honoring America's Veterans and Caring for Camp Lejeune Families Act of 2012 (Public Law 112–154; 50 U.S.C. 3953 note) is amended—

(1) in paragraph (1), by striking “December 31, 2017” and inserting “December 31, 2019”; and

(2) in paragraph (3), by striking “January 1, 2018” and inserting “January 1, 2020”.
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#2157313 - 12/14/17 06:17 PM Re: SCRA HUD Form 92070 - Expiration End of 2017 ComplyCycle
Andy_Z Offline
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This was signed 12-12-17, it's law - a 2 year extension.

Will the HUD form be updated? I won't hold my breath but I would continue to use the existing form 92070 as at least now it is correct on content.
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Rules and Regs minus Relationships equals Resentment and Rebellion. John Maxwell

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#2170890 - 03/29/18 04:47 PM Re: SCRA HUD Form 92070 - Expiration End of 2017 ComplyCycle
NoJustNo Offline
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Looks like the HUD form was upated: https://www.hud.gov/sites/dfiles/OCHCO/documents/92070.pdf

Anyone receive notification on this?

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#2170918 - 03/29/18 06:05 PM Re: SCRA HUD Form 92070 - Expiration End of 2017 ComplyCycle
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#2171096 - 03/30/18 03:36 PM Re: SCRA HUD Form 92070 - Expiration End of 2017 ComplyCycle
Andy_Z Offline
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The above link now includes a link to the updated Word version. Thanks bcompliance. There were several changes to the form.
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Rules and Regs minus Relationships equals Resentment and Rebellion. John Maxwell

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