We have an applicant who is in the military now. Any special treatment for this person. My thought was underwrite as any other loan.

The applicant is not protected by the SCRA as they are already in the military.

Thanks - I needed to verify the brain is working after HMDA/CRA.

The applicant is not protected by the SCRA as they are already in the military.

While the applicant does not qualify for the interest limitation cap, he/she still has rights under SCRA. Keep in mind there are other responsibilities on a financial institution besides capping the APR, fees, late charges at 6%.

Do we have to follow all the collection guidelines as though the loan was made prior to active duty - is that what you are referencing?

Section 108 of the SCRA:
Exercise of Rights Under Act Not to Affect Certain Future Financial Transactions.
Application by a servicemember for, or receipt by a servicemember of, a stay, postponement, or suspension pursuant to this Act 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 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 a 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 terms offered or conditions required for the issuance of insurance.

I hope that helps a little.

So would no payments made on the loan (which was made after the applicant was called to active duty) be "other considerations"?