IBA Compliance Connection

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If a customer is repeatedly delinquent on mortgage payments, are we required to continually issue the Homeownership Counseling and SCRA notices under the National Housing Act?

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Yes, you must provide this notification every time the customer becomes past due. You are required to provide the notice to a delinquent borrower no later than 45 days after the date on which the borrower becomes delinquent. If the borrower subsequently misses another payment, you again must provide the notice within the 45-day window.

For resources related to our guidance, please see below:

  • National Housing Act, 12 USC 1701x(c)(5) (notification of availability of homeownership counseling)