We have a borrower who informed his lender that he was going into the Army in May. He did not ask for a rate reduction, and he hasn't provided us a copy of his orders. He's been past due on his auto loan since March; he had intended to pay prior to active duty but that didn't work out. We are considering our next steps. Since we have knowledge, should we confirm his status thru the DOD/SCRA site and proceed to lower his rate, reamortize the payments, and reverse late charges? I would imagine we also need to stop reporting the loan as past due to the credit bureaus. I think he's young and just not aware of the SCRA protections. Under the John McCain PL, we can/should proceed even though we do not have a copy of his orders?

If he has not formally requested the relief you are not obligated to provide it. However, you are well within your rights to voluntarily provide the relief if you wish to do so.

To the best of my knowledge the SCRA does not prohibit reporting delinquent accounts to the credit bureau.