OCC Enters Consent Orders with National Bank Regarding Compliance with SCRA

Debt Collection  •  Military Service Members  •  OCC  •  SCRA

On May 29, 2015, the Office of the Comptroller of the Currency (“OCC”) entered into two consent orders with a National Bank regarding the bank’s non-home loan compliance with the Servicemembers Civil Relief Act (“SCRA”) and the bank’s practices in connection with non-home debt collection litigation practices. The OCC estimates that the bank’s practices affected approximately 73,000 customer accounts. The initial consent order alleges that the bank failed to ensure compliance with the SCRA and failed to properly administer or file certain affidavits and other sworn documents used in the bank’s debt collection litigation. The bank neither admits nor denies these allegations. A second consent order assessed a $30,000,000 civil penalty against the bank. The orders will also require that the bank institute action plans, programs, policies, and procedures to ensure and improve its compliance with the SCRA, some which must be submitted to the OCC.

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