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#1706348 - 06/04/12 08:05 PM SCRA - reporting to credit bureaus
okcowgirl Offline
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Oklahoma
Can anyone tell me what the prodical is for credit bureau reporting on active duty servicemembers?

Do you report or do you not report and where would I find this information. Thank you. All help is appreciated.

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Lending to Servicemembers (SCRA, JWNDAA), War, Terrorism
#1706658 - 06/05/12 03:25 PM Re: SCRA - reporting to credit bureaus okcowgirl
Dan Persfull Offline
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The SCRA does not prohibit reporting negative information to the CRAs.
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#1708247 - 06/07/12 09:21 PM Re: SCRA - reporting to credit bureaus okcowgirl
Andy_Z Offline
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The SCRA gives them certain rights but no where does it say they don't have to pay, or that you shouldn't report factual repayment data.

Some states, I have been told, have reporting prohibitions but I don't recall OK as being one of them. Still might be worth verifying.
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#1713243 - 06/22/12 02:16 PM Re: SCRA - reporting to credit bureaus okcowgirl
okcowgirl Offline
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Thank you both for the information.

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#1849519 - 09/06/13 05:44 PM Re: SCRA - reporting to credit bureaus okcowgirl
ItNeverEnds CRCM Offline
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I'm bringing up this thread as I have the FDIC here and they are stating that we need to update our SCRA or FCRA procedures to provide "mechanism to proactively identify service members prior to reporting negative credit information". Looking for some help as to where in SCRA or FCRA it mentions this. I'm not an expert in SCRA as we've never had a report of a service member. We have procedures in place in the event that we do, but this "proactive" piece has me confused.

Anyone have any thoughts?
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#1849850 - 09/09/13 02:14 PM Re: SCRA - reporting to credit bureaus okcowgirl
Dan Persfull Offline
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Looking for some help as to where in SCRA or FCRA it mentions this.

Ask the examiner bringing this up to provide you with the regulatory citation for such a requirement.
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#1849888 - 09/09/13 03:21 PM Re: SCRA - reporting to credit bureaus okcowgirl
ItNeverEnds CRCM Offline
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Thanks Dan, I plan to. This came at the end of the exam and at the time, I thought, ok, I've missed something as we've never had to use our SCRA procedures and I'm not overly familiar with it.
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#1850822 - 09/11/13 03:57 AM Re: SCRA - reporting to credit bureaus okcowgirl
Kathleen O. Blanchard Offline

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I am seeing this at banks, various regulators. They want banks to check before taking any kind of detrimental action to determine if customers are military (usually it is stated re collection action, repo, foreclosure, etc.) I know a number of banks that now have questions built into collections calls to ask if the individual is in the military.
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#1850848 - 09/11/13 12:58 PM Re: SCRA - reporting to credit bureaus okcowgirl
John Burnett Offline
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I certainly have no reservations about banks that build questions about military service of a debtor or spouse into their collection process. That's sensible and necessary, given the protections afforded servicemembers under the SCRA. But I have not seen any compelling reason for a creditor to make determinations of military service status prior to routine uploads of loan history to credit reporting agencies. I suspect the examiner(s) in question have overreached in their interpretations of agency focus on compliance with the SCRA.
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#1851003 - 09/11/13 04:30 PM Re: SCRA - reporting to credit bureaus John Burnett
ItNeverEnds CRCM Offline
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Originally Posted By: John Burnett
But I have not seen any compelling reason for a creditor to make determinations of military service status prior to routine uploads of loan history to credit reporting agencies. I suspect the examiner(s) in question have overreached in their interpretations of agency focus on compliance with the SCRA.


My concern is that I can't even see how this would be possible. The reporting is done automatically, so we're supposed to reach out to every client prior to reporting to the credit bureau?

I asked for clarification from the EIC a couple of days ago, but I haven't gotten a response.
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