WorkflowConsumer Loans & Cards

SCRA and MLA Compliance

SCRA compliance software that finds every covered borrower and reprices every pre-service account to 6% from the right date

Every covered borrower found, every active-duty notice repriced to 6%.

See one case, screen by screen ↓
demo$863.40refund owed from the call-up date, where servicing’s notice-date cap gave $90.71
demo38sfor six agents to read the orders, pull the DMDC certificate, find 5 accounts and back-date the cap
demo39.96%military APR found on a loan disclosed at 33.58% — blocked before signing
target1dayfrom an active-duty notice to 6% on every pre-service account, back-dated to call-up
In short

What is SCRA and MLA Compliance?

Software that finds borrowers protected by the Servicemembers Civil Relief Act and applies the relief: the 6% cap on debts taken on before service, from the date the member was called to active duty, with the excess forgiven and the payment reduced. SCRA and MLA Compliance also checks covered applicants under the Military Lending Act before they sign.

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Updated

The problem

Why active-duty notices get the wrong rate from the wrong date

Two federal laws protect service members who borrow, and they work on different clocks. At application, the Military Lending Act caps the military APR — interest plus credit insurance, debt protection, ancillary products, application and participation fees — at 36% for active-duty members and their dependants, and bans terms such as mandatory arbitration. After call-up, the Servicemembers Civil Relief Act caps every debt taken on before service at 6%, from the date the member was called to active duty, with the excess forgiven, not deferred.

The database look-up takes a minute. The rest is done by hand: reading the orders for the report date, searching every product for accounts the member holds alone or jointly with a spouse, working the interest back period by period in a spreadsheet, and catching the payment protection plan that pushes a 33.6% APR past 36%. A common shortcut — setting 6% from the day the notice arrived — leaves most of the refund unpaid, and one covered loan priced above the cap is a void contract.

target≈19daysfrom a notice to 6% when the work is done by hand
typical$500minimum actual damages per MLA violation — and the contract is void from inception
typical≈78,000service members in one student loan servicer’s 2014 SCRA settlement with the DOJ
Where a notice’s days go, from arrival to 6% on every accountestimated
By hand19 days
With the solution1 days
  • Waiting in the servicing inbox to be picked up8 → 0.1 d
  • Reading the orders and running the DMDC look-up1 → 0.1 d
  • Finding every account, joint ones too3 → 0.1 d
  • Working the interest back, period by period4 → 0.2 d
  • Letter and servicing instructions2 → 0.2 d
  • Approval and posting the credits1 → 0.3 d

Estimated split for one active-duty notice with several accounts, by hand and with the solution. Days.

How it works

How a notice moves

Six specialist agents read the orders, find every account and back-date the 6% cap to the day of call-up; the compliance analyst approves.

What comes in
Notice and application inorders + 5 accounts · letters, orders, certificates, applications
Agents at work
Notice readerdates and identity
Then
Military status checker
Account finder
Then
Interest recalculator
MAPR and terms checker
Then
Letter drafterletter + instructions
A person decides
Compliance analystapproves
What comes out
6% back to the service date
Loans blocked above 36%
Borrower letter
One case, step by step

One active-duty notice, from the servicing inbox to the borrower letter

SSgt Marcus Whitfield of the Army National Guard emails his orders to Ashgrove Bank on Friday 2 October. Servicing sets 6% on his car loan from that day. Here is what happens next, screen by screen, in the working solution.

  1. 01Monday morning

    Every notice and every covered applicant, ranked by the clock

    Danielle Okafor · SCRA and MLA compliance analyst

    Danielle opens her cases: 9 open active-duty notices, the oldest on day 20 of the bank’s 30-day policy and none past 30; 2 applications blocked before signing; $8,407 forgiven this month across 52 accounts. Each row says what the agents found — for SSgt Whitfield, “4 accounts to 6% from 14 Jul”.

  2. 02Day 10 of 30

    The ledger shows what servicing’s date would refund

    Danielle Okafor · SCRA and MLA compliance analyst

    His refund ledger opens with the cap where servicing put it: 2 October, the day the email arrived. Every statement period since he was called up sits on one line — charged at the contract rate, at 6%, and the refund. From 2 October the refund is $90.71, and the $35.00 late fee of 27 August stays on his card.

    “Refund from 2 Oct: $90.71 — $772.69 short of what the Act requires.”

  3. 03The notice

    A short email, two attachments, one account named

    SSgt Marcus Whitfield · borrower, Army National Guard

    His email of Fri 2 Oct 14:06 asks for the Servicemembers Civil Relief Act rate “to my car loan and my other accounts”, with orders 26-196-0412 and a signed request dated 29 September. The DMDC SCRA certificate, pulled at 14:09, is kept with the case. The service dates sit beside it: called to service 14 Jul 2026, expected release 17 Aug 2027.

  4. 0438 seconds

    Orders read, status confirmed, every account found

    The agents

    The notice reader lifts the report date, 14 Jul 2026, and a 400-day Title 10 mobilisation from the orders. The status checker’s DMDC certificate agrees. The account finder searches every product, alone and joint: five accounts, four opened before service — including a home equity line he holds with his spouse that his letter never mentioned — and a card opened on 21 Aug 2026, during service.

    “Finished in 38 s · 6 agents.”

  5. 05One click

    Back-date to 14 Jul and recalculate

    Danielle Okafor · SCRA and MLA compliance analyst

    The cap start date is a working control: called to active duty, letter signed or notice received. Danielle presses Back-date to 14 Jul and recalculate. The rows from July come back into the refund, part-periods split by day, and the total counts to the new figure: $743.97 credited back and $119.43 of accrued interest reversed.

    “Refund owed $863.40 — cap effective from call to active duty, not notice date.”

  6. 06Every account

    The joint line, the late fee and the card that stays put

    Interest recalculator

    Margin notes pin each finding to the rows it explains. The home equity line HE-3308-2271, joint with Kayla Whitfield, goes from 9.24% to 6% and stays there a year after release because it is secured by their home. The $35.00 late fee counts as interest and is refunded. Card 9032, opened after call-up, is not eligible for the 6% cap — it was checked under the Military Lending Act when he applied.

    Payments while he serves fall by $274.65 every month.

  7. 07The working

    Interest worked back, period by period

    Interest recalculator

    Ninety days at 6%, 14 Jul to 11 Oct, at actual days over 365. On the auto loan alone, $78.68 already billed is credited and $21.42 accrued is reversed. Each periodic payment falls by the forgiven interest — the auto loan from $582.53 to $549.96 — and the principal schedule is not accelerated.

    “Forgiven, not deferred — never billed again.”

  8. 08Approved

    One approval, the letter and the servicing instructions

    Danielle Okafor · SCRA and MLA compliance analyst

    The letter thanks SSgt Whitfield, lists all four accounts with the new rate and payment, and explains the joint home equity line and why card 9032 is unchanged. At $863.40 the refund is within her $1,000 limit, so one approval is enough. She records her reason, and the instructions go to Rosa Delgado’s team, who post each rate, credit and payment.

    Reason, kept on the record: “Orders and DMDC agree on 14 Jul; 4 pre-service debts.”

  9. 09Same family, at application

    A 33.58% APR that is really 39.96%

    MAPR and terms checker

    Kayla Whitfield, a dependant, applied online on Sun 11 Oct for a $4,500 personal loan at 27.99% with a $225 origination fee. The MLA database says she is a covered borrower. The disclosed APR is 33.58%, but the $14.50-a-month payment protection plan she chose at checkout counts in the military APR and takes it to 39.96%. The agreement also carries an arbitration clause in §14.

    Blocked before signing — the agent blocks and proposes; it never approves a loan.

  10. 10Fixed

    The covered-borrower version, back to underwriting

    Ben Tran · consumer loan underwriter

    Two fixes are proposed: offer the loan without the payment protection plan, and switch to the covered-borrower agreement v7-M with no arbitration clause and the MLA statement included. The military APR falls to 33.58% with no banned terms, the payment drops from $261.48 to $246.98, and the changed application goes to Ben Tran to approve.

Who it’s for

Built for everyone between the notice and the posted credit.

The same family’s accounts, seen by the four people who carry them — what their week looked like, and what it looks like now.

DO
Danielle OkaforSCRA and MLA compliance analyst
Analyst
Before
“The look-up takes a minute. Finding every account and working the interest back takes the afternoon.”
Now
Opens each notice on a ledger already worked back to the call-up date, every finding cited, and approves up to $1,000 on her own.
VH
Victor HaleConsumer Compliance Officer
Second approver
Before
“One borrower priced at 40% is a void contract and a headline.”
Now
Sees every account at 6%, every restoration coming due, and signs the credits above $1,000 and every rate that goes back up.
RD
Rosa DelgadoServicing operations lead
Servicing
Before
“Tell me the rate, the date and the credit, and I’ll post it.”
Now
Gets approved instructions per account — rate, effective date, credit, reversal and the new payment — and marks each one posted.
BT
Ben TranConsumer loan underwriter
Underwriter
Before
“The disclosed APR passed. I never saw the add-ons push it over.”
Now
Receives covered applications already rebuilt below 36%, on the covered-borrower agreement, with the reason for every change.
Built on the engine

6 agents. Each with one job, and hard limits.

Six specialist agents read the orders, find every account and back-date the 6% cap to the day of call-up; the compliance analyst approves.

Notice reader

Reads letters, emails, call notes and military orders: name, branch, component, order number, report date, length and expected release — with the page cited for each field.

  • Never rejects a notice for lack of orders — a commanding officer’s letter or other indicator of service counts
  • If two dates disagree, raises both
Military status checker

Runs the DMDC SCRA look-up for notices and the monthly scan, and the MLA database check at application; files every certificate with the case.

  • Never uses the MLA database to look back at an earlier transaction
  • Keeps every certificate
Account finder

Searches cards, auto loans, personal loans and home equity lines for every account the borrower holds alone or jointly with a spouse, and compares each open date with the date called to service.

  • Never leaves out a joint or closed-with-balance account
Interest recalculator

Reworks interest at 6% from the date called to service, period by period at actual days over 365, fees included; splits the excess into billed (credit back) and accrued (reverse) and sets the reduced payment.

  • Never defers — the excess is forgiven
  • Never accelerates principal
MAPR and terms checker

Builds the military APR with interest, credit insurance, debt protection, credit-related ancillary products, application and participation fees; reads the agreement for banned terms and checks the required disclosures.

  • Never approves a loan — blocks and proposes
Letter drafter

Drafts the borrower letter in plain words, the instructions to servicing and the restoration notice.

  • Never sends without a person’s approval
Compliance analyst

Approves; a second approver above $1,000 and on restorations. The agents propose; a named person decides.

Ask in plain words

Ask about any notice, account, rate or rule

The analyst can ask in plain words — or tell it what to schedule. Every answer points back to the orders, the certificate or the statement it came from.

Why does the cap start on 14 Jul and not when he wrote to us?

The Act counts from the date he was called to active duty, not from the day the notice arrives. His orders give a reporting date of 14 Jul 2026 and the DMDC certificate shows active duty from the same day. Servicing had set 6% from 2 Oct, the notice date — that refunds only $90.71 and keeps the $35.00 late fee of 27 Aug. From 14 Jul the refund is $863.40.

Why isn’t the card ending 9032 going to 6%?

Because it was opened on 21 Aug 2026, five weeks after SSgt Whitfield was called to active duty on 14 Jul. The 6% cap applies only to debts taken on before service. The card is protected another way: it was checked under the Military Lending Act at application — covered, MAPR 22.99%, MLA statement given, no arbitration. Nothing to change.

Is Kayla Whitfield’s loan within the Military Lending Act?

Not as applied. The disclosed APR is 33.58%, but the MAPR must also count the payment protection plan — $14.50 a month — which takes it to 39.96%, above the 36% cap. The agreement also has an arbitration clause in §14, which is banned for a covered borrower. Offered without the plan and on agreement v7-M, it is 33.58% and clean.

Remind me 30 days before his release to restore the rates

Done. On 18 Jul 2027 the agents will check the DMDC record; if his release on 17 Aug 2027 is confirmed, the letter drafter prepares the 30-day notice and the restoration comes to you and Victor Hale for approval. If his orders are extended, the 6% simply continues.

Every screen

The working solution, as it ships.

13 screens from the working solution, on its sample data. Pick one to see it large.

The refund ledgerOne service member’s accounts, statement period by statement period: charged at the contract rate, at 6%, and the refund — with the open notices along the top.
Back-dated to call-upThe cap moved to 14 Jul, the date on the orders and the DMDC certificate: refund owed $863.40 instead of $90.71.
Every account and every feeThe joint home equity line, the late fee refunded as interest, the card opened during service, and payments before and after.
CasesActive-duty notices, covered applicants and protections coming to an end — ranked by the 30-day clock, with what the agents found.
The noticeThe email, the orders and the DMDC certificate, the service dates that decide the refund, and every account found.
Checks runSix agents step by step — orders read, status confirmed, accounts found, the cap back-dated — and ten checks passed.
Interest worked backEach account period by period at 6%, billed credited and accrued reversed, and each payment cut by the forgiven interest.
Letter and approvalThe borrower letter, the analyst’s approval with her reason, and the instructions servicing posts account by account.
Covered applicant checkThe military APR built from every included charge, the MLA database certificate and the contract read for banned terms.
The covered-borrower versionPayment protection removed and agreement v7-M in place: military APR 33.58%, no banned terms, back to the underwriter.
Portfolio scanEvery borrower checked against the DMDC SCRA records on the first of the month; matches with no notice repriced and written to.
Protected accountsEvery account at the 6% cap, since when, the expected release and the restore date — a year later for home-secured debt.
Your rulesThe policy clock, what counts as a notice, fees during service, the covered-borrower check, the contract and the approvers.
Governance

Built for regulated work: cited, approved, on the record.

Every finding cites its documentThe report date points to the orders page, the active-duty date to the DMDC certificate, a banned term to its contract clause, a refund to its statement period.
Agents propose, a named person approvesThe compliance analyst approves each case and is named on the record with her reason. Credits above $1,000 need a second approver; a changed application goes back to the underwriter.
Nothing changes on its ownThe agents never change a rate, post a credit or send a letter themselves. Servicing posts only approved instructions, and the letter goes only when a person approves it.
Every certificate keptEach DMDC and MLA database certificate is filed with the case and the application. The MLA database is checked at application and never used to look back at an earlier transaction.
No restoration without noticeA rate goes back up only after release — a year after for debt secured by a home — with 30 days’ notice to the borrower and a second approver.
Rules versioned, cases sampledEvery change to the rules is versioned and on the audit trail, and second-line testing samples 10% of cases.
Configuration

Your military protections policy, as settings

The rules every notice and every application is checked against. Changes are versioned and on the audit trail.

SettingDefaultChoose from
Apply 6% within30 daysPolicy clock from the day a notice arrives, in days
What counts as a noticeOrders, a commander’s letter or DMDCOrders are not required — any indicator of service is accepted
Reprice on a DMDC match without a noticeOnOn · off — monthly scan applies 6% and writes to the borrower
Fees charged during serviceForgiven with the interestFees count as interest under §3937(d)
Debt secured by a home1 year after releaseProtection continues after release
Restoration notice30 days beforeBefore a rate goes back up
Covered-borrower checkMLA database, consumer report as second sourceWhen the consumer applies, or up to 30 days before
Applicant says active duty, database says noTreat as covered and ask the analystFor a self-declared covered applicant
Contract for a covered borrowerPersonal Loan Agreement v7-MNo arbitration, no SCRA waiver, no prepayment penalty
Analyst approves alone up to$1,000Above it, and on every restoration, the second approver signs
Connections

Works with the systems you already run

Servicing inbox and branchesemails, letters by post, secure messages, call notes and scanned orders
DMDC SCRA recordsstatus certificates for notices and the monthly portfolio scan
MLA databasecovered-borrower check at application, consumer report as a second source
Core banking and card platformsevery account by SSN, name and address, joint ones included
Servicing historystatement periods, fees, balances and the payment schedule
Loan agreements and fee schedulescontract terms, add-on products and covered-borrower agreements
What it changes

The difference, in numbers.

Every figure is labelled: a target the solution is built to, an estimate, a typical published result, or a proven one.

target
100%
of applicants checked against the MLA database before signing
6 of 6 applicants
certificate kept
typical
36%
military APR cap, tested with every add-on — not just the APR
APR disclosed33.58%
With add-ons39.96%
target
1day
from a notice to 6% on every pre-service account, back-dated to call-up
By hand≈ 19 days
With agents≈ 1 day

“demo” = seen in the working solution, on its sample bank data · “target” = the design goal, measured in the live solution; the ≈19-day by-hand baseline is illustrative · “estimated” = our estimate, including the split of days · “typical” = published sources: 32 CFR §232.9 (MLA: contract void from inception, actual damages of at least $500 per violation) and DOJ, United States v. Sallie Mae (D. Del. 2014, about $60 million for nearly 78,000 service members). People, the bank and accounts named on this page are fictional — characters and sample data in the working solution.

Questions

What compliance and servicing teams ask us.

What is SCRA compliance software?

Software that finds borrowers protected by the Servicemembers Civil Relief Act and applies the relief: the 6% cap on debts taken on before service, from the date the member was called to active duty, with the excess forgiven and the payment reduced. SCRA and MLA Compliance also checks covered applicants under the Military Lending Act before they sign.

How does it verify military status?

For an active-duty notice and in the monthly portfolio scan, the military status checker runs the DMDC SCRA look-up and files the certificate with the case. At application, it checks the MLA database when the consumer applies, or up to 30 days before, with a consumer report as a second source, and keeps the certificate with the application.

Which date does the 6% cap start from?

The date the member was called to active duty — not the day the notice arrives. In the working solution the cap set from the notice date refunds $90.71; back-dated to the reporting date on the orders, the refund is $863.40. The cap start is a control on the ledger, so the analyst can see the refund from each candidate date.

Does it find accounts the service member did not mention?

Yes. The account finder searches cards, auto loans, personal loans and home equity lines for every account held alone or jointly with a spouse, including accounts closed with a balance, and compares each open date with the date called to service. In the sample case it found a joint home equity line the borrower’s letter never named.

How does it test the Military Lending Act 36% cap?

The MAPR and terms checker builds the military APR from interest, credit insurance, debt protection, credit-related ancillary products, application and participation fees — not just the disclosed APR — and reads the agreement for banned terms such as arbitration. Above 36%, or with a banned term, the loan is blocked before signing and a fix is proposed.

Do the agents change rates or send letters on their own?

No. The agents propose; the compliance analyst approves each case, a second approver signs credits above $1,000 and every restoration, and the underwriter approves a changed application. Servicing posts only approved instructions, and no letter is sent without a person’s approval.

Can we set our own policy?

Yes. The policy clock, what counts as a notice, proactive repricing on a DMDC match, how fees during service are treated, the restoration notice, the covered-borrower check, the covered-borrower agreement and the approval limits are all settings, versioned and on the audit trail.

How long does it take to go live?

The Agentic Solution Engine builds and deploys it from your requirements — your military protections policy, letter templates, product list and agreements — and it goes live once every quality gate has passed. We will walk you through it on a sample of your own notices first.

See it on
your active-duty notices.

We’ll run SCRA and MLA Compliance on a sample of your own notices and covered applications.