What's the consensus out there? Are the Homeowner Counseling and/or SCRA notice required for delinquent HELOC accounts?

I'm interested in this question, too. Any thoughts?

To the best of my knowledge lien status is not a factor.

http://www.occ.treas.gov/ftp/bulletin/2003-29a.pdf

“Home loan” means a loan secured by a mortgage or lien on residential property.

Well, I could be wrong, but I think they both apply. This is how I explained it to our loan ops folks, based on the regulatory definitions:

The notice is required to be sent to "eligible homeowners." A homeowner is eligible if "the home loan is secured by property that is the principal residence (as defined by the Secretary) of the homeowner." A homeowner is defined as "a person obligated under a home loan." A home loan is defined as "a loan secured by a mortgage or lien on residential property." Residential property is defined as "a 1-family residence, including a 1-family unit in a condominium project, a membership interest and occupancy agreement in a cooperative housing project, and a manufactured home and the lot on which the home is situated."

To me, that says if the loan is secured by the customer's primary residence, regardless of lien position or whether the loan is for consumer or non-consumer purpose, the customer is entitled to the notice.