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#2181385 - 06/12/18 02:06 PM SCRA Portfolio Search
ComplyGuy Offline
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Joined: May 2015
Posts: 288
Looking for thoughts on what others are doing for SCRA. We currently perform a portfolio search of our past due loans in the DOD database, and any account that is identified as eligible we notate in the system to cease any repo activities. We would also reach out to the customer and lower the interest rate at that time.

Do others search their entire portfolio (not just past due)? We set up our process based on the idea that the key risk was the repossession/contract termination provisions and that the interest rate limitations were only required if you received written notice from the customer.

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Lending to Servicemembers (SCRA, JWNDAA), War, Terrorism
#2182000 - 06/15/18 07:50 PM Re: SCRA Portfolio Search ComplyGuy
Andy_Z Offline
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I've heard of more banks being proactive on the batch processes and checking all customers, not just past dues. In theory you're checking accounts prior to repo/foreclosure anyway. And by prior I mean just prior. There was recently a fine from DOJ because the lender had a poor process and the debtor went active duty the day before the repo took place.

So if those are checked just prior to the collection action, checking all your customers is a proactive approach to rate reductions and being aware of any other protections they may be entitled to. (And don't forget this includes your safe deposit box customers before you drill.)
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