Can anyone offer any advice on how you handle rate reductions and payment adjustments under SCRA rules when the servicemember brings in the orders a month after the service has ended. What are your processes of going backward to the start of the service and what would be the point of adjusting the payment for that time period now. Can we just change the rate effective at the start of service and re-amortize the payment from this point forward?

If a mortgage loan you have to retro the adjustment back to the beginning date of active duty and refund all interest earned above the 6% allowance and continue the relief for 12 months from the end of active duty.

If a non mortgage loan you have to retro the adjustment back to the beginning date of active duty and refund all interest earned above the 6% allowance between the beginning and ending dates of active duty.

What are your thoughts if this is an non-mortgage simple interest loan...we have changed the rate and effective dated it back retro to the active duty and the loan has done an adjustment. We are now having to change the rate back at the end of service but are we required to reamortize the remaining balance to adjust the payment as well?

I think you should make the customer whole. What would the balance and payment look like had he requested the protection timely, and had you reverted back to the contractual rate timely?

I usually focus on reamortizing based on the scheduled maturity date.

Agreed.