SCRA Protection – credit card through third party

Compliance > Lending > Service Members > SCRA
Q: What if a bank offers a credit card through a third party? The credit card balances do not sit on the bank’s books. Does the bank have to reduce the interest rate on those accounts?
 
A:  The obligation to reduce the interest rate and payments under section 527 of the SCRA rests with the creditor. If the financial institution is the creditor, it is responsible for ensuring that the third party reduces the interest rate and payment.
 
 
ADDITIONAL INFORMATION – This Q&A was released by the Federal Reserve Board, in follow up to their Servicemember Financial Protection Webinar that was presented on September 10, 2012 - https://www.consumercomplianceoutlook.org/2013/first-quarter/servicemember-financial-protection-webinar/
 

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