Our bank policy/procedures are to pull a MLA search on ALL borrowers. If they have a military status, we write the loan at 6% or less regardless if the borrower has an "Active" status. With that being said, would we need to pull a SCRA search? Is that an requirement that we obtain a SCRA search?
MLA requires more than just a specific interest rate. In fact, the 6% rate you mention is an SCRA requirement that only applies to pre-service debt. MLA requires calculation and disclosure of a MAPR, which includes things that are not included in the APR. It also caps MAPR at a maximum of 36%. It also requires specific oral and written disclosures be provided. You should pull a MLA determination before making any consumer purpose loan covered under MLA.
SCRA, on the other hand, provides for interest rate relief to a rate no higher than 6%, but that is only for pre-service debt. SCRA does have protections in the event of default and collections, foreclosure, or repossession activities. These protections apply to all debt as long as the borrower is on active duty (or for a specified time after active duty for certain types of debt). You should pull a determination of SCRA status before undertaking any collection, foreclosure, or repossession activities.