2021 citi recovery supplier training for the

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

Information will not create an attorney-client or other privileged or confidential relationship, except to the extent that

relationship may already exist. To the extent federal, state or local laws or regulations apply to your company, your

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

Privileged and Confidential, Property of Citigroup Inc. 2

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


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


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


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.


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


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


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


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 More than one-half of their support for the 180 days immediately preceding

application for relief under this Act



Knowledge Check


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


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


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


Who can activate the SCRA?

1. Commanding Officer

2. Spouse

3. Mother/Father

4. Friend

5. All of the above

Knowledge Check


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


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


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


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


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


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


Congratulations! You have completed Citi’s Supplier training for the

Servicemembers Civil Relief Act.

Conclusion


2021 citi recovery supplier training for the

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