The ML 2006-28 actually says the letter isto, "Be sent to all homeowners who are in default on a residential mortgage;" In this case the homeowner and the person in default are two different people. I would also say that the services offered in the counseling by Military OneSource and SCRA benefits belong to the servicemember and not the homeowner.
If I was sending it to one or the other I'd go with the SM and leave it that way as making a disclosure like this has no ill effect if it isn't applicable. I would maintain that (I believe) the counselling is available for other than mortgage debts but this notice addresses mortgages, not personal debts. You could also have potential privacy issues when you tell the homeowner the SM is not paying. I've never really figured out a good solution to that argument as the homeowner should be made aware, in my opinion.
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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