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#2221783 - 09/17/19 09:31 PM HUD SCRA Notice Disclosure
Texas Prof Offline
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Is HUD's SCRA Notice Disclosure to be provided on all delinquent consumer mortgage loans, or just those secured by HUD?

In reading through the regulation and supporting materials, I've encountered disagreement on the statement that "All mortgage loans, including conventional mortgages and mortgages insured by HUD are subject to the notification requirement." I’m interpreting this as “all mortgage loans, regardless of whether or not they are HUD-secured,” while a colleague is interpreting it as “all mortgage loans, only if they are HUD-secured.”

Any thoughts?

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#2221791 - 09/18/19 12:26 PM Re: HUD SCRA Notice Disclosure Texas Prof
rlcarey Offline
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https://consumercomplianceoutlook.org/2011/fourth-quarter/servicemembers/

It has actually been required on all mortgage loans since 2006, I believe. HUD was just in charge of developing the notice for all lenders.
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#2221815 - 09/18/19 02:27 PM Re: HUD SCRA Notice Disclosure rlcarey
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Thank you!

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#2222048 - 09/20/19 10:11 PM Re: HUD SCRA Notice Disclosure Texas Prof
Andy_Z Offline
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From the original instructions on Mortgagee Letter 2006-28:

All mortgage loans, including conventional mortgages and mortgages insured by HUD are subject to the notification requirement that became effective June 5, 2006. The notice must:

• Be sent to all homeowners who are in default on a residential mortgage;
• Include the toll-free Military OneSource number to call if servicemembers or their dependents require further assistance (1-800-342-9647); and
• Be made within 45 days from the date a missed payment was due, unless the homeowner pays the overdue amount before the expiration of the 45-day period.
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#2224326 - 10/24/19 04:19 PM Re: HUD SCRA Notice Disclosure Texas Prof
It's not easy Offline
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I'm transitioning into the commercial world, so forgive me if this appears to be a stupid question, but if the collateral is their home but is a commercial loan, it wouldn't need the HUD - 90280 disclosure on any past due notices but they would still need to a military check prior to any repossessions or foreclosures, correct? Thanks everyone! I really appreciate all your knowledge!

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#2224563 - 10/28/19 06:18 PM Re: HUD SCRA Notice Disclosure Texas Prof
It's not easy Offline
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I found the answers within the link below in case anyone is interested. Thanks!

https://consumercomplianceoutlook.org/2013/first-quarter/servicemember-financial-protection-webinar/

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