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#700097 - 03/12/07 08:16 PM SCRA notice revisited (reinterpreted?)
jap Offline
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Does everyone agree with the BOL guru Q&A (in this week's weekly briefing) regarding the new SCRA notice required by HUD? This seems to contradict the direction others have stated receiving from HUD.
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#700947 - 03/14/07 01:58 PM Re: SCRA notice revisited (reinterpreted?) jap
LoisLane Offline
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Is it under the Lending tab?
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#700952 - 03/14/07 02:02 PM Re: SCRA notice revisited (reinterpreted?) LoisLane
LoisLane Offline
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OK, found it under the Compliance Tab
...addresses only those covered loans to "servicemembers" and their spouses jointly....

The problem as I understand it, is that we don't always know which loans are to servicemembers (because not all of them notify us) and likewise with spouses. For this reason, to comply, the notice has to go to all consumer borrowers.
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#703757 - 03/20/07 07:27 PM Re: SCRA notice revisited (reinterpreted?) LoisLane
ToTo Offline
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I'd like to bring this up once again. Has anyone noticed that this new HUD form (Servicemembers Civil Relief Act Notice Disclosure) has an expiration date on it (upper right corner) of 4/30/2007 ("exp 4/30/2007")? Can anyone comment on that?

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#703814 - 03/20/07 08:52 PM Re: SCRA notice revisited (reinterpreted?) jap
BobZ Offline
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I disagree with the guru's guidance that HUD Mortgagee Letter 2006-28 addressess only those covered loans to "servicemembers" and their spouses jointly. Unless I'm misinterpreting the guidance, it states that the " The notice must be sent to all homeowners who are in default on a residential mortgage". I've emailed the guru for clarification and have not received a response. Does anyone else have any thoughts on this?

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#707097 - 03/27/07 02:41 PM Re: SCRA notice revisited (reinterpreted?) BobZ
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See this Federal Register post 03/26 as referenced in an article on complianceheadquarters.com.

http://a257.g.akamaitech.net/7/257/2422/01jan20071800/edocket.access.gpo.gov/2007/E7-5412.htm

The first paragraph in this link says

"Notice is to be provided to all homeowners who are in default in order to inform them of mortgage and foreclosure rights available to them under the SCRA if they are servicemembers or dependents of servicemembers."

The rest of it is IDENTICAL to the November posting, including the "All mortgages" statement referenced above.
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#708423 - 03/29/07 11:42 AM Re: SCRA notice revisited (reinterpreted?) StevenD
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I am also wondering about the 4/30/07 date...

We also give it to ALL loans in default as we wouldn't know if they fall under SCRA.
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#708427 - 03/29/07 12:04 PM Re: SCRA notice revisited (reinterpreted?) DeeQ
jap Offline
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I went to the link and didn't see a 4/30/07 date...where did you see this?
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#708428 - 03/29/07 12:12 PM Re: SCRA notice revisited (reinterpreted?) jap
DeeQ Offline
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#709448 - 03/30/07 06:28 PM Re: SCRA notice revisited (reinterpreted?) DeeQ
BeachGirl Offline
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What was the required date to begin sending this notice?

Thanks!
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#709579 - 03/30/07 08:40 PM Re: SCRA notice revisited (reinterpreted?) BeachGirl
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HUD issued a letter detailing this new requirement on November 20, 2006.
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#709756 - 04/02/07 01:43 PM Re: SCRA notice revisited (reinterpreted?) Sinatra Fan
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The question should be - are loans in which the bank has not been notified, but will be sometime in the future in arrears, subject to SCRA? Don't the servicemembers receive counseling? I know that when I had my last command records check, they had a station set up and went over that.

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#711780 - 04/05/07 02:06 PM Re: SCRA notice revisited (reinterpreted?)
Silent Valley Offline
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Which model language do we use, the one on the HUD web site or the one that was published in the FR on 03/26/07? There are differences.
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#731061 - 05/14/07 02:03 PM Re: SCRA notice revisited (reinterpreted?) Silent Valley
Nanwa Offline
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Can we just attach this wording to our Homeownership Counseling notice? Shouldn't we be giving this notice to everyone, in case the service person neglected to get us copies of their orders?
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#731066 - 05/14/07 02:06 PM Re: SCRA notice revisited (reinterpreted?) DeeQ
Nanwa Offline
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DQ, do you include the notice with the Homeownership Counseling notice, or do you send a separate one?
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#734048 - 05/17/07 01:08 PM Re: SCRA notice revisited (reinterpreted?) BeachGirl
Nanwa Offline
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I just received an update to our software which includes an SCRA notice. HOWEVER, it is the original HUD notice from the Mortgagee Letter 2006-28. The wording in the March 2007 Federal Register is different. It includes dependents instead of just spouses, includes the website of Military One Source, and the phone numbers are different. I wenmt online to Military One Source, and it appears the Fed Reg numbers are the correct ones.

Which notice do we use?
Last edited by Nanwa; 05/17/07 01:09 PM.
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#735052 - 05/17/07 09:24 PM Re: SCRA notice revisited (reinterpreted?) Nanwa
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I've instructed our staff to use the wording from the Federal Register. The form that was posted on HUD's web site had an OMB expiration date of 4/2007 when I saw it a few months ago. I haven't checked to see if they updated it.
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#735219 - 05/18/07 12:25 PM Re: SCRA notice revisited (reinterpreted?) Reads Regs
Nanwa Offline
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I am surprised that ITI didn't catch that, and sent the old notice with its recent update. But, regulations change, sometimes too much and too fast.
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