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The media headlines I have been seeing recently are both dunning banks for violating the SCRA in various ways or ensuring servicemembers understand their rights to benefits, which your bank pays for. In either case your bank needs to be aware of this environment. Whether you like it or not your bank has a military mission because the servicemembers who bank with you are as good as a protected class of borrowers. If you say, “we don’t have servicemembers,” while you may be correct today, will that be a correct statement tomorrow, do you know if any customers enlisted yesterday or were called to active duty? Asking what needs to be done when you get a request, is too late. You need the right skillset new. Plus, your examiners want to see procedures so you’ll know how to react when you do have one, or a hundred SMs on your books.
When making a MLA covered loan, you need to know who is in the military or a qualified dependent. So, who are these borrowers and what’s a covered loan? You can’t avoid them anymore, you just CYA and march on. And banks just can’t seem to keep the SCRA straight. In this webinar, Andy will discuss the rules and how to comply with both the SCRA and MLA to avoid violations of the laws.
While many military lending enforcement actions are typically not against banks like yours, your examiners still want to see complete compliance. That means clearly understanding the compliance requirements of the MLA and SCRA and having effective lines of communication between affected areas in your institution, and well-designed policies, procedures, training, and execution.
If you are not sure you have a complete understanding of the protections servicemembers have, this webinar is designed for you.
The MLA and SCRA protections extend beyond servicemembers, and in some cases beyond loans, reaching deposit accounts and even safe deposit boxes. The MLA affects you before you make a loan, while the SCRA largely impacts your existing relationships. We will discuss specific protections and early warning signals of problems that need to be addressed. You have an opportunity to learn from the mistakes of others.
You want to protect your customers; you also want to avoid problems with examiners who will want to discuss your policies and procedures for addressing servicemembers’ rights. You need to understand what your procedures must address, who must be trained, how to respond to inquiries, and more.
In this webinar we will review the rules addressing:
- When the MLA applies
- Why the SCRA exists, with practical examples
- How the MLA and SCRA protect servicemembers and dependents
- How to properly identify covered borrowers and dependents
- Which sections of the SCRA and MLA affect your bank the most
- What lessons can be learned from thousands of complaints and enforcement actions
- Notice requirements from HUD
- What you must do and what you cannot do on covered transactions
- Why complaints are early warning signals of things your examiner will review
- The confusion over the HUD – SCRA mortgage form
- And much more.
If you have a customer in the military, a reservist who could be activated or one who might enlist, if you have questions on when they can request an interest rate change or delay a foreclosure, join Andy for this two-hour webinar.
Questions and Answers