Serious question- when do we stop sending these notices?
If the borrower is initially past due for his 1/1/22 payment, we send the HUD-SCRA notice say on 1/31/22. He doesn't make the 2/1/22 payment, now he is 31 days past due for 1/1/22 and 1 day past due for 2/1/22. Then he doesn't make the 3/1/22 payment, he is 60 days past due for 1/1/22, 30 days past due for 2/1/22 and 1 day past due for 3/1/22. We send the HUD-SCRA notice again at 60 days past due for 1/1/22, 30 days past due for 2/1/22 - to be within 45 days of 2/1/22 and 90 days of 1/1/22.
As this goes on at some point he is 120 days past due for 1/1/22 but less than 45 days or 90 days past due for the other payments. Do we have to continue sending HUD-SCRA notices for the other payments that are missed? What if we have started loss mitigation or they are in BK?
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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