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#2273528 - 07/28/22 04:00 PM SCRA - Cash Secured Credit
JLubach Offline
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Joined: Sep 2015
Posts: 14
We have two products that I want to be sure we are applying SCRA rules correctly - Cash Secured Installment Loan and Cash Secured Revolving Line of Credit
SCRA: once the request has been made for interest rate reduction we need to

* Calculate and refund all interest paid above 6% from date of inception through date account changed to 6%
* Reamortize and modify note to reflect new interest rate of 6% and new payments
* Late payments may be reported to credit reporting agencies
* Cannot close account for default (and use funds securing account for payoff/pay down) without a court order

Are the above statements valid and is there anything else we are missing?
Thank you in advance!

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#2273530 - 07/28/22 04:42 PM Re: SCRA - Cash Secured Credit JLubach
rlcarey Offline
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rlcarey
Joined: Jul 2001
Posts: 83,396
Galveston, TX
* Calculate and refund all interest paid above 6% from date of inception through date account changed to 6%

What do you mean by "from date of inception"? Inception of what?
_________________________
The opinions expressed here should not be construed to be those of my employer: PPDocs.com

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#2273532 - 07/28/22 05:00 PM Re: SCRA - Cash Secured Credit rlcarey
JLubach Offline
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Joined: Sep 2015
Posts: 14
date loan originated

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#2273533 - 07/28/22 05:01 PM Re: SCRA - Cash Secured Credit JLubach
rlcarey Offline
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rlcarey
Joined: Jul 2001
Posts: 83,396
Galveston, TX
Why would you go back to the date of origination? You only go back to the date of entering active service.
_________________________
The opinions expressed here should not be construed to be those of my employer: PPDocs.com

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#2273534 - 07/28/22 05:22 PM Re: SCRA - Cash Secured Credit rlcarey
JLubach Offline
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Joined: Sep 2015
Posts: 14
thank you - that is clarification I needed

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