She said: "We've done this on all of our cards and none of the others have asked for anything like you have."

You said: "Management wants to make a gesture, though, so I think we are going to honor the request as of the noitification date and grant the reduced rate going forward."

And it's no wonder SCRA compliance is all over the board. It's a nice "thank you for your service" gesture, but it's contrary to the requirements as the pre-service balance of the SMs debt gets the protections. I would hope you would point this out to your customer in a way that say, "our analysis of the account indicate that because...there are no SCRA interest rate protections due but we do appreciate your service and will therefore..."

You should also plan on changing any other accounts where you believe the borrower is in the service, IMHO, to be fair, unles the squeaky wheel is the only one to get greased.

OK... I just had a heart attack in an MLA meeting... I guess I want to see if I'm missing something (major insomnia last night, so I could be) before I start asking some serious questions.

In clearing up some confusion between SCRA and MLA someone said something like 'well, currently when we reduce the rate on a credit card, we block the card so they can't incur any more debt at such a low rate.'

I think I'm having a mini stroke over this one.... please tell me if I'm missing something here.

Under SCRA, the rate reduction applies to debt incurred prior to military service. So, you would not be required to apply the 6% to any credit card debt incurred after they became active. Either they don't understand how it works, or perhaps they think it's too complicated to have different rates? Regardless, I don't see any legal basis for blocking the card for new purchases because the borrower invoked their SCRA rights. I think this is a huge problem.

Thank you Shellfish - I agree!

Our system (many years ago) couldn't handle two rates so we moved the entire balance and future charges to 6%. I'd have a hard time believing systems today couldn't handle two rates. I'd say if you blocked further charges, a) Reg B AAN would be required and b) you could be be in violation of 3919, https://www.bankersonline.com/regulations/scra-3919 for denying credit when the SCRA protections are invoked.

Hopefully this was a mis-statement.

Thank you Andy for providing that link - I had not made my way there yet to research. I too am hoping it was a big mis-understanding!