Servicemember issues have been in the news for a few years now. Financial Institutions have been taking great care not to treat servicemembers and their family members less favorably, due to the great compliance and reputation risks problems in this area present. But what exactly are the rules?
The Servicemembers Civil Relief Act (SCRA) is the most well-known, of course. But there are other considerations, such as fair lending and even UDAAP. And the new Military Lending Act (MLA) regulations have kicked in. These rules will introduce significant new requirements for ALL lenders, whether they know it or not yet. Lenders that believe they don’t have issues to deal with for military customers may unfortunately be taken by surprise.
Does your institution know the rules, and what to do and not do? This webinar is designed to address all these issues, and especially the new MLA rules, so you can be prepared. Know what it means to reduce the interest rate on active duty borrowers to 6%, as well as various other protections against foreclosure and other areas. Know how to determine whether you have a "covered borrower" under the MLA and SCRA, as the standards are different.
We'll also talk about some of the more-recent enforcement actions taken against other institutions, to learn from others' mistakes.
- MLA rules - what are they all about?
- Verifying status under the MLA and SCRA
- What do we have to do when someone is covered?
- Caps and rate restrictions under the rules
- Principal SCRA protections, including the interest rate reduction provision
- What does active duty mean? How do you know for sure who is covered? Plus, who is NOT covered?
- Dealing with the DMDC website to confirm status
- Permanent Change of Station (PCS) guidance
- When does coverage end? Does it?
- Foreclosure and default judgment protections
- HUD Form 92070 - what it is and when to provide it
- Protection against eviction
- Steps to take now
Anyone in the institution that might encounter Servicemembers and Servicemember accounts. This includes frontline staff, managers, auditors, lenders, and underwriters.
Carl Pry is a Certified Regulatory Compliance Manager (CRCM) and Certified Risk Professional (CRP) who is a Managing Director for Treliant Risk Advisors in Washington, DC. Through his working career, as well as through his experience as a banking attorney and officer, he has provided a variety of regulatory compliance and financial performance services to financial institutions and other clients throughout the country. He has written extensively regarding consumer and commercial compliance, tax, audit, and financial institution legal issues, and is a frequent contributor to and currently serves on the Editorial Advisory Board for the ABA Bank Compliance magazine. He has spoken at scores of banking, compliance, and state bar associations, and has conducted training sessions for financial institutions across the country.
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