SCRA Protection – HARP and refinance

Compliance > Lending > Service Members > SCRA
Q: If our bank provides a new refinance loan under the Home Affordable Refinance Program (HARP), the loan origination date is now after the start of military service and the service member no longer qualifies for the 6 percent reduction. Is there an exception to this?
 
A:  To date*, an exception to the policy has not been necessary because borrowers who refinance under HARP obtain a rate well below the 6 percent rate provided for under the SCRA provisions. Only if the market interest rate increases above the 6 percent threshold would it be necessary to consider a waiver allowing the origination date of the loan to be after the military start date.
 
*This ”to date” response was provided in connection with the September 2012 webinar noted below.
 
 
 
ADDITIONAL INFORMATION – This Q&A was released by the Federal Reserve Board, in follow up to their Servicemember Financial Protection Webinar that was presented on September 10, 2012 - https://www.consumercomplianceoutlook.org/2013/first-quarter/servicemember-financial-protection-webinar/
 

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