2021 citi recovery supplier training for the
TRANSCRIPT
2021 Citi Recovery Supplier Training for the
Servicemembers Civil Relief Act (SCRA)
The information contained in this training material (“Information”) is provided for general information purposes only. It
should not be relied upon or construed as legal advice, and it is not a substitute for obtaining competent legal or
compliance direction from counsel. The inclusion or omission of any material within the Information shall not be deemed
to waive any of Citi’s rights or your company’s obligations pursuant to any agreements entered into between Citi and your
company, including but not limited to your company’s obligation to comply with Citi’s policies, Citi’s instructions and
applicable law and regulation. In addition, the submission of an inquiry or email to any Citi personnel regarding the
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company is responsible for ensuring compliance and adherence to said laws or regulations where applicable. Citi makes
no representation as to the suitability, reliability, and/or accuracy of the Information, and is provided “as is” without
warranty of any kind. To the maximum extent permitted by applicable law, in no event shall Citi be liable for any direct,
indirect, punitive, incidental, special, consequential damages or any damages whatsoever in connection with the use of
the Information.
In the following pages, you will be guided through a series of lessons that cover compliance with Servicemembers Civil Relief Act (SCRA).
By the end of this course, you will be able to:
• Define active duty
• State that SCRA was enacted in order to avoid causing financial hardship or financial disadvantage to servicemembers called to active duty.
State that SCRA:
a) Restricts or limits legal action against a servicemember while he/she is in active military service
b) Prohibits adverse reporting based solely on military duty
c) Covers many protections not all of which are only for pre-service obligations
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By the end of this course, you will be able to:
• Explain that SCRA benefits are effective for an eligible servicemember on the date the servicemember was called to active duty (or for a reservist, on the date of notice)
• Relate how a notice of active duty can be submitted up to 180 days after conclusion of active duty. If submitted after the servicemember’s return from active duty, benefits are retro active
• Explain the types of debts covered by SCRA
• Recognize fee and interest rate limitations established by SCRA
Objective
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The Soldier and Sailor’s Civil Relief Act (SSCRA) was a United States law that
was enacted in 1940 and updated after the Gulf War of 1991. The law required
lenders to provide assistance to those military personnel that experienced financial
hardship as a result of their service in the United States of America uniformed
services.
In 2003 the Service Members Civil Relief Act (SCRA) was signed into law as a
complete revision of the SSCRA, it incorporates many years of judicial
interpretation of the SSCRA, and updates the SSCRA to reflect new developments
in American life since 1940.
SCRA Background
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SCRA provides assistance to servicemembers, or the servicemember and their
spouse jointly, who incurred debt PRIOR to being called to or entering active duty
in the military. With respect to interest rate reductions to 6%, SCRA provides
assistance…
Some SCRA provisions also apply to dependents of a servicemember:
• Servicemember’s spouse
• Servicemember’s child
• With respect to interest rates on obligations, upon notice provided by the
servicemember, the SCRA provides assistance by requiring that the interest
rate be lowered to 6% for an obligation incurred by a servicemember or the
servicemember’s spouse jointly, before the servicemember entered military
service during the period of military service, and for one year thereafter for
mortgage/deeds of trust.
To Whom SCRA Applies
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The term “active duty, or “active service”, is defined by the US Code, Title 10,
Section 101 as full time duty in the active military service of the United States.
Such terms include full time training duty, annual training duty, and attendance,
while in the active military service, at a school designated as a service school by
law or by the Secretary of the military department concerned.
Military service begins on the date the servicemember receives the order to report
for active duty.
SCRA “Active Duty”
Active duty means the date the
servicemember receives the order to report
to the armed forces, which is referred to as
the “date of the Orders” or “Being Called to
Active Military Service” and ends on the date
the servicemember is released from military
services or dies while in military service.
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Servicemembers are members on active duty in the
uniformed services that include:
• Army
• Air force
• Navy
• Coast Guard
• Marine Corp
• National Guard (those reserves called to service for more than 30 consecutive days under Section 502(f) for purposes of responding to a national emergency declared by the President and supported by Federal funds.)
• Commissioned officers in the Public Health
Services and the National Oceanic and
Atmospheric Administration in active service
• Military reservists who are ordered to report for active duty.
Defining Servicemember
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Why was the SCRA enacted as a law?
Select the correct answer:
1. It was enacted as an incentive for people to join the armed forces.
2. It was enacted to avoid causing financial hardship or financial disadvantage to
servicemembers called to active duty.
3. It was enacted as part of the financial benefits provided to servicemembers
who are serving active duty.
4. It was enacted to provide financial help to families that have lost a family
member who was serving active duty.
5. None of the above.
Knowledge Check
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Servicemembers in the following uniformed service(s) may become eligible for
SCRA assistance.
Select all that apply:
❑ Coast Guard
❑ National Guardsman on weekend training mission
❑ National Guardsman called to service for more than 30 consecutive days
❑ Marine Corps
❑ Commissioned officers in the National Oceanic and Atmospheric Administration
❑ Navy
❑ Air Force
❑ Army
❑ Commissioned officers in the Public Health Service
Knowledge Check
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Some SCRA provisions also apply to dependents of Servicemembers. Some
provisions may apply to an individual whom a Servicemember provides more than
one-half of their support immediately preceding application for relief under this Act.
What is the period of time that a dependent must receive support in order to be
included in a Servicemember’s SCRA benefits?
o One-half of their support for the 120 days immediately preceding application for
relief under this Act
o One-half of their support for the 200 days immediately preceding application for
relief under this Act
o More than one-half of their support for the 180 days immediately preceding
application for relief under this Act
o One-half of their support for the 90 days immediately preceding application for
relief under this Act
Knowledge Check
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Pursuant to the SCRA statute,
Servicemembers who are requesting
the activation of the 6% interest rate
limitation, are required to provide us
with a written request to activate such
benefit as well as a copy of their
written orders calling them to active
duty in the military or extending their
current military service.
Their request and written orders can
be received no later than 180 days
after the servicemember’s termination
or servicemember’s release from
service.
Activation of SCRA Benefits
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The request for SCRA benefits
activation does not have to come
directly from the servicemember being
called to active duty. Anyone can
make the request to activate the
benefits allowed by the SCRA.
Examples of those who may request
benefit activation on behalf of a
servicemember are:
• Commanding Officer
• Spouse
• Mother/Father
• Brother/Sister
• Friend
Requesting SCRA Benefits
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When are SCRA benefits effective for an eligible servicemember?
1. 180 days after starting effective duty
2. At any time a servicemember is a member of the armed services
3. At the time of discharge from active military service
4. After full retirement from the armed forces
5. On the date the servicemember is called to active duty (or for reservists, on the
date the servicemember receives notice)
Knowledge Check
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Who can activate the SCRA?
1. Commanding Officer
2. Spouse
3. Mother/Father
4. Friend
5. All of the above
Knowledge Check
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For the servicemember and servicemember’s spouse who jointly incurred debt PRIOR to the servicemember entering active military service, SCRA requires:
• Ensure that the interest rate on the account does not exceed 6% during the period of military service.
• The amount of any periodic payment due shall be reduced by the amount of the interest forgiven
• Within SCRA, interest is defined as including late fees, service charges, renewal charges or any other charges with respect to the obligation or liability on the account. Bonafide insurance fees are not included in the SCRA definition of interest.
• Forgive (not defer) the interest between the contracted loan interest rate and the 6% interest rate per year requirement of the SCRA.
Protections Provided by SCRA
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For a servicemember and a servicemember’s
spouse who jointly incurred debt PRIOR to entering
active military service, SCRA requires:
• In the case of foreclosure the stay and
protection is for the time of active duty and
one year thereafter.
• Preserve the servicemember’s credit rating
by:
o Refraining from taking any legal
actions such as eviction, repossession
and foreclosure without a court order.
o Refrain from reporting the account
adversely to the bureaus solely
because the customer is in the
military.
Protections-Continued
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Examples of protections afforded
under the statute for
servicemembers who activate
SCRA benefits are:
• Outstanding credit card debt
• Installment loan debt (e.g.
mortgage, auto, student loans)
• Pending civil actions
• Taxes
• Termination of leases
Protected Obligations
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Select all statements that apply to SCRA.
A. Covers debt incurred during the term of active military service.
B. Covers debt incurred prior to the call to active military service.
C. Prevents servicemember’s credit from being negatively impacted.
D. Provides free legal services for servicemembers that have financial hardship
due to their military service.
E. Provides lower interest rates to all military personnel who have at one time
been on active duty.
Knowledge Check
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While anyone can request SCRA coverage for another person, Citi’s privacy policy
remains intact and an agent cannot discuss the servicemember’s account
information with the requestor. For complete details on how to respond to SCRA
related inquiries, please review Citi’s Supplier Work Standards.
SCRA Handling
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As of October, 2017 the Military Lending Act (MLA) also put certain requirements
in place for credit that is issued to active military members and their family.
• Prohibits an APR greater than 36%, military annual percentage rate (MAPR),
on many types of credit
• Defines what must be included when calculating the MAPR
• Limits when/if the customer can be required to submit disputes for arbitration
• Defines certain disclosures that must be provided to the customer at origination
SCRA Handling
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Congratulations! You have completed Citi’s Supplier training for the
Servicemembers Civil Relief Act.
Conclusion
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