Compliance with the Servicemembers Civil Relief Act (SCRA) and Military Lending Act (MLA) is a high priority area for the second term of the Trump Administration. This emphasis was first articulated in the Consumer Financial Protection Bureau’s April 2025 memo on supervision and enforcement priorities, which states that the Bureau will focus its resources on pressing threats to consumers, “particularly service members and their families, and veterans.”

Recent federal activity also signals renewed supervisory and enforcement attention on SCRA compliance. The SCRA examination handbook has been updated and the Department of Justice (DOJ) has issued numerous SCRA enforcement actions over the past year. Additionally, private SCRA litigation continues to remain elevated, and is increasing with more class action lawsuits and legal theories testing long-standing compliance assumptions. These three key developments and their compliance implications are discussed in more detail below.

Taken together, these developments underscore the need for financial institutions to ensure SCRA compliance programs are up-to-date, address recent hot issues and misunderstandings, and are being followed!

• What does “active duty” mean?  It isn’t as clear as it used to be.
• Are our collections personnel aware of the requirements?
• Are our servicing personnel aware of the requirements?
• What are our responsibilities up front upon receiving a loan application vs. our responsibilities for loans already on our books?
• What are the differences between the SCRA and MLA compliance requirements?
• When does the service member have to initiate a request for their rights vs when does our Financial Institution have to proactively identify and comply with a member’s (or their family’s) rights?
• Recent use of the National Guard and military activity has increased the applicability of these requirements – even for small, community financial institutions!
• And more . . .

Compliance with the Servicemembers Civil Relief Act is a high-priority area for the second term of the Trump administration. Recent federal activity also signals renewed supervisory and enforcement attention on SCRA compliance.

Presenters:

Jennifer Cliber Smith, CRCM, Compliance Anchor Director

Jeremy C. Sairsingh, Troutman Pepper Locke

Nicholas Carter, Troutman Pepper Locke

Jason Manning, Troutman Pepper Locke

WHO SHOULD ATTEND: Compliance Officers, Risk Officers, Senior Lenders, Lending Officers, Enterprise Risk Officers and personnel, Credit Risk personnel, Collections personnel, Auto and Indirect Lending Officers and personnel, Mortgage Servicing personnel