As we have been reporting, the CFPB has made the Servicemembers Civil Relief Act (SCRA) a major focus and instructs its examiners to look at SCRA compliance during examinations. The OCC has also stepped up its focus on SCRA compliance during examinations of national banks and federal savings associations, according to recent remarks by an OCC official at the 2014 Association of Military Banks of America Workshop.
In her remarks, Grovetta Gardineer, Deputy Comptroller for Compliance Policy, indicated that the OCC’s stepped up SCRA focus responds to the significant risk associated with an institution’s failure to comply with SCRA requirements. Ms. Gardineer stated that because of that risk, the OCC now requires its examiners “to include evaluation of SCRA compliance during every supervisory cycle.”
In its Bulletin 2014-37 on Consumer Debt Sales issued earlier this month, the OCC included SCRA accounts as a type of account that banks should refrain from selling.