We have a customer that is on active duty and is past due. We have lowered the rate as required. He has a savings account here. Can we set-off against his savings account?

What does your loan documents say about right of set-off. Also you need to review your deposit agreement.

Our loan docs and deposit agreement give us the right to offset. I just don't know if there is anything in the SCRA that would prevent us from the offset.

You best get your attorney involved. All collection actions are subject to the stays allotted in the SCRA.

Exercising your right of set off would be similar to a foreclosure or repossession of the servicemember's property.