the security the individual can , and has received and submitted the applicable documentation using the DMDC , a federally regulated and actively updated database , can offer comparable amounts of security without much of the hassle .
Develop Comprehensive and Periodic Indicators of SCRA Interest Rate Reduction Utilization
According to the CFPB , SCRA utilization has been lower than it could be . In light of this , the CFPB has suggested financial institutions develop individual programs to monitor and identify patterns in SCRA usage by consumers .
This is not the same as a SCRA compliance audit , but rather a suggestion to develop a supplemental program to determine how many of the financial institution ’ s consumers are active duty utilizing their SCRA rights . If the financial institution finds a large portion of their consumers are active duty , but not utilizing their SCRA rights , the financial institution could consider modifying any existing marketing or disclosure language regarding the SCRA , or developing new programming suited for that particular member base . Even if the financial institution decides not to change marketing or programming , they will have a compilation of data regarding their members who may be in the service .
Moving Forward
Although many financial institutions offer SCRA benefits , for a myriad of reasons , many servicemembers fail to receive them . SCRA compliance audits offer financial institutions a grade on whether their program follows federal regulations but does not offer any information regarding utilization .
The SCRA began as a way to repay those who serve the United States , and as a powerful set of rights to offset certain negative events while in active duty . By better aiding our servicemembers , financial institutions can be a part of a movement to ensure SCRA rights are awarded to those who deserve them .
The CFPB has found and released a data report regarding the underutilization , which indicates this could be on their radar for compliance in the future . In response , this should also be on financial institutions ’ radar from now on , in tandem with their original SCRA program . Having a comprehensive SCRA program is beneficial for the financial institution , but without proper utilization , it cannot fully assist those who it was intended to benefit . •••
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