During an audit of SCRA, we discovered that customers are not sent a Change in Terms notice each time their orders are extended. For example, the customer received orders in November 2022; we received the orders in January 2023 and sent a Change in Terms with the following language.

"Modification to adjust the interest rate to 600% and re-amortize the payments due to active military orders during the period of relief. Relief period is November 30, 2022, through September 8, 2023. New payment amount during the relief period will be $809.87 beginning with the February 14, 2023 payment. Following the end of the relief period, the terms will revert to the original terms of the note. All other terms and conditions remain the same."

We received a new set of orders in July 2023 that extended active duty until September 2024. Should we have sent a new Change in Terms to the customer? What if there had been a break in service? For example, the new orders started from November 2023 to September 2024. We usually don’t increase the rate after the customer leaves active duty.

We send a letter each time we are notified active duty is extended, including the interest rate and payment. When a customer is no longer on active duty, we send a letter stating when the old interest rate and payment amount will be reinstated.

Thank you.