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!