SCRA and MLA compliance, explained.

The SCRA's 6% cap and the MLA's 36% limit, explained through one mobilized Guard soldier's loans

The life of one active-duty notice, in five steps

1. A member is called to serviceStaff Sergeant Kellerby's Guard unit is mobilized. His orders, dated June 2, 2026, tell him to report on July 14 for 400 days.
2. The lender hears about itAn email with his orders reaches the servicing inbox on October 2. It names one loan; the bank holds five accounts in his name.
3. The relief is worked out and appliedStatus confirmed, every pre-service account found, interest reworked at 6% from the start date, payments cut. This is where $90.71 becomes $863.40, or does not.
4. The member is told, and the credits postA letter lists every account, the new rate, the refund and the new payment.
5. Service ends, and the rate comes backExpected release August 17, 2027. The car loan and card can return to their contract rates the next day; the home equity line stays at 6% for another year.

Step 3 is the subject of this guide, with the MLA check that happens before a new loan is signed. The people, bank and figures in this example are fictional.

SCRA and MLA facts that surprise lenders

Servicemember, covered borrower, MAPR and DMDC certificate

Fourteen terms are defined in the one-page summary.

Who the SCRA and the MLA protect, and when protection starts and stops

In shortThe SCRA protects people in military service, including Guard and Reserve members on federal orders, and in some cases their spouses; for its 6% cap the debt must predate service. The MLA protects active-duty members and their dependents at the moment they take on new consumer credit. The groups overlap, and for a reservist SCRA protection can begin before active duty does.

About 1.35 million people were on active duty in March 2026, with 771,200 more in the reserves, according to Defense Manpower Data Center figures published by USAFacts.11 Every consumer lender meets them, and their families, on both sides of the two laws.

The SCRA: service, plus the debts that came before it

The SCRA's money protections follow the person into service. Regular active-duty members are covered while they serve. Guard and Reserve members are covered when called to federal active duty under Title 10 of the US Code (federal orders), including training orders, and Guard members called up for more than 30 consecutive days under 32 U.S.C. 502(f), on orders authorized by the President or the Secretary of Defense, to respond to a national emergency declared by the President.2,1

For a reservist the clock can start early: under 50 U.S.C. 3917, a reserve member ordered to report gets the protections "beginning on the date of the member's receipt of the order".7 The Justice Department and the CFPB read that to cover the rate cap: "For military reservists, protections begin upon the receipt of certain military orders, which may occur months before the entry into active duty."2

The 6% cap applies to obligations "incurred by a servicemember, or the servicemember and the servicemember's spouse jointly", before service.1 A spouse who co-signed is protected on that joint debt.2 A debt the member took on after service began is not capped, though it may be covered by the MLA.

Protection ends with service, with two tails for veterans: the member can still ask for the rate cut up to 180 days after release, and on a mortgage the 6% runs for a year after release.1,2

The MLA: active duty, at the moment of borrowing

A covered borrower under the MLA is, at the moment the credit is taken out, a member on active duty under Title 10, 14 or 32 under orders that do not specify 30 days or fewer, or on Active Guard and Reserve duty, or a dependent of such a member: a spouse, certain children and certain other people the member supports.13

Status is fixed at application. A borrower who leaves the service stops being covered for later dealings, and the lender may not look someone up in the Defense database after the account is open to find out whether they were covered on an earlier date.13,14

The MLA does not cover residential mortgages, loans to buy a car or other goods that are secured by what is bought, or credit outside Regulation Z (the Truth in Lending rule). The SCRA's 6% cap applies to all of those when they predate service.13,2

The statutes, rules and guidance behind military lending compliance, and what changed in 2025 and 2026

In shortThe SCRA's rate rules have not changed since 2018, and the Defense Department has not touched its MLA rule since a 2020 interpretation. What changed is around them: the CFPB withdrew its 2021 rule on MLA examinations and saw its funding cap cut almost in half in 2025, the OCC rewrote its SCRA exam booklet in November 2025, and the Justice Department kept settling SCRA cases into October 2026.

How to calculate an SCRA refund: four accounts, ninety days, one late fee

In shortFor each statement period since service began, charge the balance at the contract rate and again at 6%, using actual days. The difference is the refund. Credit what was already billed, reverse what has accrued and not been billed, cut each payment by the interest above 6%, and treat fees charged during service as interest.

The statute gives four instructions. Interest above 6% "shall be forgiven". The cap applies from the date of call to service. The periodic payment is "reduced by the amount of the interest forgiven" for that period. And "interest" includes "service charges, renewal charges, fees, or any other charges (except bona fide insurance)".1 The OCC's 2021 SCRA exam booklet told examiners that banks "may need to decrease or eliminate fees and other charges, such as annual fees", to stay within the cap.26

One period of one loan

Take Staff Sergeant Kellerby's car loan, at 8.49% on a balance of $16,629.23 for the 31 days from July 22 to August 21, 2026. At the contract rate: $16,629.23 × 8.49% × 31 ÷ 365 = $119.91. At 6%: $16,629.23 × 6% × 31 ÷ 365 = $84.74. The member is owed $35.17 for that period. Repeat for every period since July 14 and the car loan comes to $100.10: $78.68 already billed, to credit back, and $21.42 accrued since the last statement, to reverse.

The fictional example, July 14 to October 11, 2026, actual days over 365, each period rounded to the cent. The bank in the example treats the $35 late fee of August 27 as interest under §3937(d) and refunds it.

The payment has to fall too

The statute requires each periodic payment to drop by the forgiven interest for its period, so the member is not paying down principal faster than the contract planned. For an installment loan, the new payment is the old one less a month of interest above 6% on the current balance: the car loan's $15,696.18 × 2.49% ÷ 12 = $32.57, so $582.53 becomes $549.96. On an interest-only home equity line, the whole payment is interest and falls from $242.39 to $157.40.1,2

Why the start date decides most of an SCRA refund

In shortThe cap runs from the date of call to service, which for a Guard or Reserve member can be the day the orders were received. The day the lender hears of it usually comes months later, and counting from it under-pays. In the example, starting from the email date pays $90.71; starting from the reporting date pays $863.40.

When the notice arrived, servicing set 6% from October 2, the day of the email. It is a common shortcut, and it under-pays every time a member writes after service began, which is nearly always. The statute is explicit: the lender applies the cap "effective as of the date on which the servicemember is called to military service".1

The Village Capital settlement of October 19, 2026 turned on the same point: the Justice Department alleges the servicer failed to cut rates to 6% "retroactively to the date they received their military orders" and failed to cut payments.6

The dates in one notice

When orders and the DMDC certificate give different dates

Orders may give a report date, a date of issue and an "effective" date; the DMDC certificate may show a different start, or nothing yet; amended orders may extend service without the database catching up.2 The safe course is to take the earliest date the documents support and record why. Among the records the OCC's 2021 SCRA booklet says a bank might keep are "the dates of military service for servicemembers who request SCRA benefits" and "the calculation of benefits".26

What the DMDC SCRA website shows, and what it can miss

In shortLenders check status on the DMDC SCRA website using the person's last name with a Social Security number or date of birth, and keep the certificate. Since 2018 the statute lets a lender rely on that check if it shows no active duty and no notice arrives within 180 days of release. It has gaps: some Title 10 periods, short orders and amended orders do not appear, and a member's own documents always win.

The Defense Manpower Data Center runs two lookup sites: one for the SCRA and one for the MLA.26 A lender enters the last name with a Social Security number, a date of birth or both (a search without the number is less certain) and gets a status report for the date asked:28 on active duty or not, and when active duty began and ended. The lender saves the report as its certificate.

Since August 13, 2018, a lender may verify service itself using "information retrieved from the Defense Manpower Data Center" instead of waiting for the member's documents. If the DMDC record shows the person not in service and no notice arrives by 180 days after release, the lender has not broken the rate rule.1,26 The OCC's 2021 booklet warned that errors in how the bank searches, or in the details it uses, "may not … protect the bank"; the November 2025 update revised the verification provisions.26,18

What the database misses, in the regulators' words

• "The DMDC SCRA website only reports Title 10 active duty periods", and "not every period of Title 10 active duty will appear", "particularly active duty periods of less than 30 days".2
• Orders "are amended to extend the period of AD, which would extend SCRA protections, but may not be captured by the DMDC".2
• If the member sends a notice and an indicator of service within 180 days of release, "the creditor must provide the SCRA's interest rate benefit even if the DMDC does not show a period of active service". The safe harbor "applies only when the creditor has not received the written notice".2

The same letter recommends going further than the law: "proactively checking accounts using the DMDC and automatically applying the SCRA interest rate cap to all eligible servicemembers", and applying it to every eligible account once a member asks about one.2 Federal student loan servicers have matched borrowers against DMDC monthly since 2014; the GAO found that more than twice as many borrowers benefited from the automatic process as had applied in writing before it.8

How to calculate the military APR, and why it differs from the APR on the disclosure

In shortStart from the Truth in Lending finance charge, then add credit insurance, debt cancellation or suspension fees, credit-related add-on products, and application and participation fees, even where Regulation Z leaves them out. Compute the rate with the APR method. If it is above 36%, the loan cannot be made to a covered borrower as written.

The rule names what goes in. Section 232.4(c) counts "credit insurance premiums or fees", fees for "debt cancellation contracts or debt suspension agreements", fees for "credit-related ancillary products sold in connection with the credit", and, subject to a narrow exception for credit card fees, finance charges, application fees and participation fees. They count "even if" Regulation Z would exclude them from the finance charge.3 For closed-end credit the rate is computed the way Regulation Z computes an APR; for a card, it is computed for each billing cycle.3

Kayla Kellerby's application

She applied online on Sunday, October 11, 2026 for $4,500 over 24 months at 27.99%, with a $225 origination fee withheld from the loan, so she receives $4,275. The payment is $246.98, and the disclosed APR, which counts the interest and the fee, is 33.58%. At checkout she ticked a payment protection plan at $14.50 a month. The disclosure does not count it; the MAPR must. With the plan, she pays $261.48 a month for 24 months to receive $4,275, a military APR of 39.96%.

Three fixes are open: drop the plan, lower the price, or decline. The plan cannot be kept by calling it optional, because the rule counts add-ons "sold in connection with" the credit. The CFPB's 2023 Supervisory Highlights found installment lenders that had not confirmed "several thousand borrowers" were not covered, creating the risk of loans "at rates and terms impermissible" under the MLA.29

Credit cards and the bona fide fee rule

Card fees get one exception: a "bona fide" fee that is reasonable for its type stays out of the MAPR. A fee at or below the average charged by five or more large card issuers is a safe harbor. Insurance, debt protection and add-on product fees can never use it, and if a card charges a fee that is not bona fide, every fee goes back in.3

The MLA covered-borrower check, the banned contract terms and the disclosures owed

In shortA lender is protected if it checks covered status through the Defense database or a nationwide consumer report when the person applies, or within 30 days before, and keeps the record. A covered borrower's contract may not contain arbitration, waivers of rights, prepayment penalties or several other terms, and must come with a written and spoken statement of the MAPR.

The check, and its timing

Any method may be used, but two give a safe harbor: the Defense Department's MLA database, searched with "last name, date of birth, and Social Security number", or a status flag in a report from a nationwide consumer reporting agency.14

The check counts only if made when "a consumer initiates the transaction or 30 days prior to that time" (or when the account is applied for), or for a firm offer of credit, if the consumer responds within 60 days. The lender must create "and thereafter maintain" a record of the result. After the account is open, the lender may not use the database to find out whether the person was covered on the earlier date.14

Terms a covered borrower's contract may not contain

What must be said, and how

Before or when the borrower becomes obligated, the lender gives a statement of the MAPR (a model statement opens "Federal law provides important protections to members of the Armed Forces and their dependents"), the Regulation Z disclosures, and "a clear description of the payment obligation". The MAPR statement and the payment description go in writing the borrower can keep and orally, in person or through a toll-free number printed on the application or the disclosure.24

The SCRA protections beyond the rate cap: default judgments, foreclosure, repossession and leases

In shortBefore a default judgment, a lender must file an affidavit on the defendant's military status. A pre-service mortgage cannot be foreclosed during service or for a year after without a court order, and a car bought with a pre-service deposit cannot be repossessed during service without one. Members may end car and home leases early without a penalty.

• Default judgments. In any civil case where the defendant does not appear, the plaintiff must file an affidavit saying whether the defendant is in military service, with the facts behind it. If the defendant appears to be serving, the court appoints a lawyer and may stay the case for at least 90 days. A false affidavit is a crime.20 In May 2026 a rental company settled with the Justice Department over a false military-service affidavit that led to a default eviction judgment against an active-duty sailor.30
• Foreclosure. For a mortgage that "originated before the period of the servicemember's military service", a sale, foreclosure or seizure "during, or within one year after" service is not valid without a court order or a waiver. The one-year period has been permanent since 2018.15
• Repossession. If a deposit or installment was paid before service on a purchase or lease, including a car, the creditor may not repossess for a breach "without a court order".21 Hyundai Capital America (November 2024, 26 vehicles), New City Funding (September 2025) and CarMax (February 2026, 28 vehicles) all settled over repossessions without court orders.30,31
• Lease termination. A member may end a car lease when entering service under orders of 180 days or more, or on a permanent change of station outside the continental United States or a deployment of 180 days or more. The vehicle goes back within 15 days of notice, no early termination charge is allowed, and rent paid in advance is refunded within 30 days. Notice may be sent electronically.22

SCRA and MLA enforcement since 2020: the Justice Department's cases and the CFPB's retreat

In shortThe Justice Department enforces the SCRA and kept settling cases through 2025 and 2026, from repossessions to a mortgage servicer's rate cap. The CFPB enforces the MLA; it closed its two big MLA lawsuits in 2025, one with a $4 million penalty and one with $1.75 million in redress, while withdrawing its MLA exam rule and losing much of its budget.

The Justice Department: steady, and now about the rate cap again

Many recent SCRA cases against creditors are about cars: repossessions without court orders. The October 2026 Village Capital settlement brought the rate cap back to the front.

The Justice Department alleges the VA loan servicer did not cut rates to 6% back to the date servicemembers received their orders, did not cut payments, told some borrowers their rates were already below 6% when they were not, and accelerated principal and reported loans delinquent to the VA after servicemembers asked for the benefit. The settlement covers at least 41 servicemembers' mortgages: at least $425,000 to the servicemembers and a $79,380 civil penalty, which the release calls "the maximum penalty for a first violation of the SCRA".6

The older cases set the patterns lenders still follow. Under a 2014 consent order in the Justice Department's Sallie Mae case, 77,795 servicemembers began receiving $60 million for excess student loan interest in June 2015; the SCRA part of the 2012 National Mortgage Settlement with five large servicers made 2,413 servicemembers and co-borrowers eligible for over $311 million for foreclosures without the required court process.32,33 Consent orders in these cases often require a lender to apply the 6% to every eligible account once a member asks about one.2

The CFPB: two MLA cases closed, supervision pulled back

• FirstCash. Sued November 12, 2021 for pawn loans to covered borrowers above the 36% MAPR, arbitration clauses and missing disclosures. A stipulated judgment entered July 11, 2025 requires full redress, a $4,000,000 civil money penalty, and either an MLA-compliant product or the safe-harbor screen. The 2013 order against its predecessor Cash America was terminated on July 22, 2025.17
• MoneyLion. Sued September 29, 2022 over charges that put covered borrowers above the 36% MAPR and over missing disclosures. A stipulated judgment entered November 24, 2025 requires $1.75 million in consumer redress; the CFPB's page names no penalty.19
• The CFPB's own count. "In 2025, the CFPB resolved three separate actions to address violations of the Military Lending Act." In the same year its own table counts 22 actions where it terminated or modified an order or issued a no-action letter, and 19 it dismissed or withdrew from.27

For banks, the practical result is that MLA and SCRA compliance is examined by their prudential regulator (OCC, FDIC, Federal Reserve or NCUA), tested by the Justice Department through cases, and enforced by borrowers through private suits, where the MLA's void-contract rule and $500 minimum make claims easy to bring.5,18

The SCRA and MLA mistakes that keep showing up in exams, cases and data

In shortLenders start the cap on the wrong date, fix one account and miss the rest, defer instead of forgiving, leave fees in, forget the payment cut, lose track of release dates, trust the database over the member's documents, and price covered loans without counting the add-ons. The CFPB's data suggest most eligible reservists never get the cut at all.

The CFPB's 2022 study matched activated Guard and Reserve members to their credit records. Even at its peak by length of activation, the share of eligible auto and personal loans cut to 6% stayed under 16%. The unclaimed savings averaged $331 per activation on an auto loan and $249 on a personal loan; in its worked example, a $168,000 mortgage at 6.5% to 7.5% would forgo $1,890 to $5,670 per activation.8

Some reductions may not show in the credit data (reporting errors, or cuts applied back in time), so the true rate may be somewhat higher.

The ten most common mistakes

What the data say about servicemembers as borrowers

In shortServicemembers borrow more for cars, put less down, buy more add-ons and pay slightly higher rates than other borrowers with the same lenders. Complaints from the military community reached about 84,600 in 2023. No public figure says how often lenders apply the SCRA correctly.

The CFPB's January 2025 report on six auto lenders' loans from 2018 to 2022 found servicemembers financed about $39,000 for a new vehicle, more than $2,200 above other borrowers, and more often traded in a car worth less than the loan. Over 70% of both groups bought at least one add-on product.34

The same report shows how a change in interpretation moves a market. Guaranteed asset protection (GAP) products were in under 10% of servicemembers' auto loans in 2018 and 2019, and in over 40% from after the first quarter of 2020 to the end of 2022, after a Defense Department change to its interpretive rule on GAP and the MLA.34 That February 28, 2020 interpretive rule (85 FR 11842) is the Defense Department's last Federal Register action on the MLA rule, 32 CFR part 232, as of October 2026.25

The manual route an active-duty notice takes: five roles, four hand-offs and a spreadsheet

In shortNotices arrive anywhere: mail, email, branches, the phone. A servicing or compliance analyst verifies status, reads the orders, searches for accounts, works the refund in a spreadsheet and drafts a letter; servicing posts the changes; a compliance officer approves the larger ones. At application, underwriting relies on a database check and the disclosure system. Most of the time goes to waiting and to finding and recalculating accounts.

Servicing, compliance, underwriting and legal: who handles military borrowers

Four hands between an active-duty notice and the member's letter

Waiting and searching: the 19 days of a hand-worked notice

A desk spreadsheet, a verification service or servicing platform features

Five screens that turn a $90.71 refund into the $863.40 Staff Sergeant Kellerby is owed

In shortThis is the example from the top of the page, inside the product. Six agents read the email and the orders, pull the DMDC certificate, find five accounts and rework the interest. Danielle Okafor, the SCRA and MLA compliance analyst, sees servicing's notice-date refund of $90.71 beside the documents, back-dates the cap to July 14, checks the working and approves $863.40. Servicing posts what she approved.

1

Every notice and covered applicant, ranked by the clock

Monday morning, October 12. Danielle's queue holds nine open active-duty notices, the oldest on day 20 of the bank's 30-day policy and none past it, two applications blocked before signing, and $8,407 forgiven this month across 52 accounts.

Each row says what was found. For Staff Sergeant Kellerby: "4 accounts to 6% from Jul 14 · refund $863.40". The next row is a spouse's joint auto loan; the third, orders with no report date.

2

The refund as servicing left it: $90.71

His case opens on a before-and-after table of every statement period since he was called up: charged at the contract rate, charged at 6%, and the refund. It starts with the cap where servicing put it, October 2, the day the email arrived.

From that date the refund is $90.71, and the $35 late fee of August 27 stays on his card. The banner says what that misses: "$772.69 short of what the Act requires". Above it, a timeline puts every date that matters on one line, from the 2019 card to his release.

3

Two documents, one date

The notice reader lifted the dates from page 1 of the orders: report July 14, 2026, 400 days, Title 10, expected release August 17, 2027. The military status checker's DMDC certificate, pulled at 2:09 pm on October 2, shows active duty from July 14. Both open from the margin notes, each field highlighted.

The orders are dated June 2. For a Guard member, protection can start when the orders are received (Part A, section 5), so this is the place to ask him when they arrived.

4

Back-dated to July 14 in one click

The cap start is a working control: called to active duty, letter signed, or notice received. Danielle presses "Back-date to Jul 14 and recalculate". The July and August rows come back into the refund, part-periods split by day, the late fee drops out, and the total counts up to the new figure.

The banner now reads "Refund owed $863.40", with the cap running from the call to active duty: $743.97 to credit back and $119.43 of accrued interest to reverse.

5

One approval, the letter and the servicing instructions

The letter drafter wrote to him in plain words: four accounts, each with its new rate, refund and payment, the joint home equity line explained, and why the card opened on August 21 stays as it is. At $863.40 the refund is inside Danielle's $1,000 limit, so one approval is enough. She records her reason: "Orders and DMDC agree on Jul 14; 4 pre-service debts."

Instructions go to Rosa Delgado's servicing team account by account: rate, effective date, credit, reversal, new payment. Each is marked posted.

How the refund is worked: the joint line, the late fee and the card that stays put

In shortThe account finder searched cards, auto loans, personal loans and home equity lines for anything in his name, alone or joint. The interest recalculator reworked every period at actual days over 365, split billed from accrued, counted the late fee and set the new payments. Every figure on the letter comes from the same working.

His letter named the car loan. The account finder found four accounts opened before July 14 and one opened after. The home equity line is in both names, his and Kayla's, and the statute covers debts "incurred by a servicemember, or the servicemember and the servicemember's spouse jointly".1 Because it is secured by their home, it stays at 6% for a year after his release.

The card ending 9032 was opened on August 21, during service, so the 6% cap does not reach it. The bank checked that card under the Military Lending Act when he applied: military APR 22.99%.

The same family at application: a 33.58% loan with a 39.96% military APR

In shortKayla Kellerby's online application was checked against the MLA database the moment she applied: covered, as a servicemember's spouse. The MAPR and terms checker rebuilt the rate with her payment protection plan and read the agreement. It blocked the loan before signing and proposed two fixes; the underwriter approves the changed application.

The certificate was searched with last name, date of birth and Social Security number at 7:42 pm on Sunday, October 11, two minutes after she applied, and filed with the application. That is the safe harbor in 32 CFR 232.5.14

Interest of $1,427.41, the $225 origination fee and $348 of protection plan charges come to $2,000.41: a military APR of 39.96%. Two fixes are proposed. Offer the loan without the plan: military APR 33.58%, payment $261.48 down to $246.98. Use the covered-borrower agreement, version 7-M, with no arbitration clause and the MLA statement included.

The checker never approves a loan. It blocks and proposes; the underwriter decides, and the disclosures owed under §232.6 are listed for the closing.

Beyond one notice: the monthly DMDC scan, the accounts at 6% and the bank's own rules

In shortEvery borrower is checked against the DMDC SCRA records on the first of the month, and matches with no notice on file are repriced and written to, as the Justice Department and the CFPB recommend. Every protected account shows when it may be restored. The bank's policy lives in settings, versioned.

Repricing on a DMDC match without a notice goes further than the statute requires; it is the proactive check the December 2024 Justice Department and CFPB letter recommends (Part A, section 6).2 The scan keeps a certificate for every borrower checked, and a match whose date of birth differs by one digit goes to a person.

How SCRA notices and MLA checks split between agents and signers

In shortSix agents read, check, search, calculate and draft; none of them changes a rate, posts a credit or sends a letter. The compliance analyst approves each case, a second approver signs credits above $1,000 and every restoration, and the underwriter decides changed applications. Every finding cites its document.

Six agents read the notice, check DMDC, find accounts and recalculate

The analyst, compliance officer and underwriter who sign

Approvals record the name, the decision, the reason and the time. Agent steps and human decisions are kept apart on the audit trail; certificates stay with the case; rule changes are versioned; second-line testing can sample cases.

Member letters, DMDC results and account history the review reads

DMDC, servicing and origination systems it works beside

Danielle Okafor's SCRA and MLA desk

Design targets for active-duty notices and MAPR checks

What a wrong start date, a missed account or a mispriced loan costs a lender

In shortEach SCRA mistake is owed back to the member, often with remediation across a whole portfolio, and a Justice Department case adds a penalty of up to $79,380 for a first violation. An MLA mistake voids the contract and carries at least $500 per violation. The time cost sits with your analysts and is rarely measured.

Find your own under-refunds, missed accounts and MLA exposure

Portfolio lookbacks, void contracts and lost member trust

What automating active-duty notices and covered-borrower checks could return

In shortPut in your own numbers. The value comes from analyst hours saved on every notice and covered application, and from remediation you no longer need because refunds start on the right date. Every default here is illustrative; replace it with what you measure.

Notices worked on arrival, MAPR built before signing

Formulas: notice time saved = N × max(0, h0 − h1) × w · application time saved = A × m ÷ 60 × w · remediation avoided = N × p% × r · net = the three savings − c.

The refunds themselves are owed to members either way and are not counted as savings. The defaults are illustrative: the hours echo the example's estimate, the cost per hour is an assumption to replace with your own loaded rate, and no source publishes an under-refund rate for banks. With the defaults, 400 notices save 1,700 hours of notice work; at 100 notices and 3 hours today, the time saving is $12,375.

How ready is your SCRA and MLA desk for software? Start dates, account search, MAPR builds and records

In shortScore each question 0, 1 or 2. Most of the readiness is in knowing your volume, having one owner for the policy, and being able to reach every product system by SSN. The ninth question is for reflection.

Next steps for your SCRA and MLA desk by score

Questions to ask any SCRA compliance software vendor, and a twelve-week pilot

In shortAsk every vendor, us included, to work your own past notices and covered applications in front of you. The questions below separate a system that flips a rate from one that finds every account, starts on the right date and leaves evidence. Then pilot for twelve weeks against a measured baseline.

A twelve-week SCRA and MLA pilot: re-work 20 closed notices and 25 covered loans, run in parallel, then decide

Start dates, refunds to the cent and MAPR accuracy in the pilot

The 6% cap, back-dated refunds, fees, spouses, DMDC checks and the 36% MAPR: SCRA and MLA questions answered

In shortThe questions servicing teams, compliance officers and buyers search for most, each answered on its own.