Compliance Alliance Q&A 8/20/2019

Question:

For SCRA purposes, if a customer we know has been called into service comes into the bank to lower their rate, does the bank have to require proof of military service? 

 

Answer:

No - there is not an actual requirement to collect or file proof of military status as license to reduce the rate under the SCRA. However, the bank may have internal procedures mandating personnel to do so, and this is quite common in the industry. In addition, ensure that if the bank does have a policy related to this, that it is applied consistently for fair lending purposes. 

 

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