Author: Cody Roberts, CRCM
Banks are mired down with many acronyms lately (TRID and CFPB to name a few). However, one that has gotten some scrutiny lately is the SCRA, or the Servicemembers Civil Relief Act. Notable banks supervised by the OCC that have been included in enforcement actions include Bank of America, JPMorgan Chase and Capital One.
The most recent example of SCRA scrutiny was publicized in May of 2015. The OCC assessed a $30 million civil money penalty against Bank of America and ordered remediation to approximately 73,000 affected customer accounts. Primarily, the enforcement action was intended to correct deficiencies in the bank’s practices and procedures related to its SCRA-compliance program and address the preparation and notarization of affidavits and other sworn documents used in the bank’s debt collection litigation. The action also directed the bank to improve its SCRA-compliance policies and procedures for determining whether military personnel are eligible for requested SCRA-related benefits, ensuring the bank calculates the SCRA benefits correctly and verifying the military status of servicemembers prior to seeking or obtaining default judgments on non-home loans. Also, the enforcement action directed the bank to improve its enterprise-wide compliance risk management program.
Here at ABS, we strive to help institutions with their SCRA compliance with our CompliancePro® software. The product contains procedures and up-to-date file reviews backed by a staff of compliance experts. For more information, please feel free to contact us at 800.522.4990 or visit https://www.americanbanksystems.com/.
