SCRA Notice

Posted By: Many Hats

SCRA Notice - 04/06/12 02:26 PM

If we put this statement on our 30 day past due reminder notices (for consumer dwelling secured loans), would this be sufficient to comply with the SCRA notice requirements?

“The Servicemember Civil Rights Act (SCRA) protects all servicemembers and their dependents from undue hardship resulting from the service member not being able to meet their financial obligations due to being away on active duty in the military service. If you believe you may qualify, please see our website @ www.bank.com or contact our Compliance Officer @ ###-###-#### to receive a full copy of the Servicemember Civil Rights Act Notice Disclosure.”

Or, would you recommend sending the actual HUD notice itself?
Posted By: Dan Persfull

Re: SCRA Notice - 04/06/12 03:17 PM

The above would not be compliant. It's your responsibility to provide the notice, not the borrower's responsibility to contact you and ask for it.
Posted By: ComplytillIdie

Re: SCRA Notice - 04/26/12 05:06 PM

I'm trying to audit the content of our SCRA Notice (HUD-92070)...where can I find exam procedures or the specifications for that form? Ii've checked FDIC HUD Exam Guide and SCRA Exam Guide and I don't see it in either.

I know a revised form was recently issued and I have that, but my forms vendor has only used one of the bullet points in the last section dealing contact information for obtaining legal assistance from the website. I have been unable to find guidance on what types of customization a lender can make to this notice.

Please advise.
Posted By: rlcarey

Re: SCRA Notice - 04/26/12 05:11 PM

http://portal.hud.gov/hudportal/documents/huddoc?id=92070.doc

It's an OMB form, I am not aware that it can be changed.
Posted By: ComplytillIdie

Re: SCRA Notice - 04/26/12 05:23 PM

Great...I'll just give them the sample form and make them prove to me that it can be altered...

On to the next crisis...so many regulations, so little time. :-)

Thanks for the help!