Skip to content
BOL Conferences
Thread Options
#2221783 - 09/17/19 09:31 PM HUD SCRA Notice Disclosure
Texas Prof Offline
Junior Member
Joined: Sep 2016
Posts: 32
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?

Return to Top
Lending to Servicemembers (SCRA, JWNDAA), War, Terrorism
#2221791 - 09/18/19 12:26 PM Re: HUD SCRA Notice Disclosure Texas Prof
rlcarey Online
10K Club
rlcarey
Joined: Jul 2001
Posts: 83,219
Galveston, TX
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.
_________________________
The opinions expressed here should not be construed to be those of my employer: PPDocs.com

Return to Top
#2221815 - 09/18/19 02:27 PM Re: HUD SCRA Notice Disclosure rlcarey
Texas Prof Offline
Junior Member
Joined: Sep 2016
Posts: 32
Thank you!

Return to Top
#2222048 - 09/20/19 10:11 PM Re: HUD SCRA Notice Disclosure Texas Prof
Andy_Z Offline
10K Club
Andy_Z
Joined: Oct 2000
Posts: 27,748
On the Net
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.
_________________________
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

Return to Top
#2224326 - 10/24/19 04:19 PM Re: HUD SCRA Notice Disclosure Texas Prof
It's not easy Offline
100 Club
Joined: May 2009
Posts: 127
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!

Return to Top
#2224563 - 10/28/19 06:18 PM Re: HUD SCRA Notice Disclosure Texas Prof
It's not easy Offline
100 Club
Joined: May 2009
Posts: 127
I found the answers within the link below in case anyone is interested. Thanks!

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

Return to Top

Moderator:  Andy_Z