Although we will suspend foreclosure or repossession due to delinquency if borrower is an active duty servicemember, we would continue to submit monthly reports on the delinquency to the credit bureaus. Although we do not have, and never have had, a suspended foreclosure or repo due to SCRA protections, the continued credit bureau reporting in our procedure is being questioned, in that this practice would not be in line with SCRA and that such reporting should also be suspended until the servicemember's duty is terminated.

I have reviewed the SCRA and did not locate where the bank is prohibited from reporting the delinquency information. Are there any others of you who are suspending the credit reporting once aware of the SCRA protections from foreclosures?

There is no federal prohibition on reporting the accurate payment history of a servicemember. They still are required to pay and unless a state prohibition exists you should report an accurate history under the FCRA.

Thank you Andy Z.

what about section 3919 (3)?

§ 3919. Exercise of rights under chapter not to affect certain future financial transactions.
[Section 108 of the Act]
Application by a servicemember for, or receipt by a servicemember of, a stay, postponement, or suspension pursuant to this chapter in the payment of a tax, fine, penalty, insurance premium, or other civil obligation or liability of that servicemember shall not itself (without regard to other considerations) provide the basis for any of the following:

(1) A determination by a lender or other person that the servicemember is unable to pay the civil obligation or liability in accordance with its terms.

(2) With respect to a credit transaction between a creditor and the servicemember--

(A) a denial or revocation of credit by the creditor;
(B) a change by the creditor in the terms of an existing credit arrangement; or
(C) a refusal by the creditor to grant credit to the servicemember in substantially the amount or on substantially the terms requested.

(3) An adverse report relating to the creditworthiness of the servicemember by or to a person engaged in the practice of assembling or evaluating consumer credit information.

(4) A refusal by an insurer to insure the servicemember.

(5) An annotation in a servicemember's record by a creditor or a person engaged in the practice of assembling or evaluating consumer credit information, identifying the servicemember as a member of the National Guard or a reserve component.

(6) A change in the terms offered or conditions required for the issuance of insurance.

Although I do see this article does back up Andy Z...
https://www.lockelord.com/~/media/857B1C86E7F84794A1F75C3A325D0BCE.ashx
(When SCRA and FCRA Collide)

You can't adversely report them because they use the law, you adversely report them because they don't pay.

Say they pay at 6%, you can't say they're past due because the payment as contracted at 9%.

Just read your linked item, and yes, that is what I'm saying.

Thanks Andy, much appreciated.