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January 5th, 2017, 01:02 PM
Super Moderator
 
Join Date: Mar 2012
Re: scra and regulation z

Well the interaction of Regulation (Reg) Z and Servicemembers Civil Relief Act (SCRA) says that credit unions think of the member's compliance to SCRA and Reg Z after learning their military affiliation or plan to go in active duty.

It states that SCRA's provision on interest-rate limitation trigger certain requirements under Reg Z and the U.S. Truth in Lending Act.

SCRA requires six percent reduction in interest rate for obligations incurred before an active duty.

SCRA Interest Rate Limitations

SCRA caps interest rate charges, including late fees and other transaction fees, at 6 percent.

The MLA limits interest rates and fees to 36 percent MAPR (Military Annual Percentage Rate).

The MAPR is not just the interest rate on the loan, but also includes additional fees and charges including:

Credit insurance premiums/fees

Debt cancellation contract fees

Debt suspension agreement fees and

Fees associated with ancillary products.

The Department of Housing and Urban Development (HUD) requires that SCRA disclosures be provided by mortgage servicers on mortgages at 45 days of delinquency.

This disclosure must be provided in written format only.


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