PCS orders to move to a new duty station present unique challenges for military homeowners, particularly in cases where their homes have declined in value.
The Agencies have concerns about the following types of practices which have the potential to mislead or otherwise cause harm to military homeowners receiving PCS orders:
- Failing to clearly and timely communicate available assistance options, provide a reasonable means to learn the status of requests, and providing timely decisions on requests for assistance with reasons for any denial;
- Asking homeowners with PCS orders to waive legal rights in order to be evaluated for assistance; and
- Advising homeowners to skip payments to create the appearance of financial difficulty to qualify for assistance for which they would not otherwise qualify.
Financial institutions that engage in residential mortgage servicing should maintain appropriate policies, procedures, and training commensurate with the institution's customer base and the size and complexity of its operations, to ensure that their employees respond appropriately to requests for assistance from military homeowners receiving PCS orders.
Chief Executive Officer
Chief Compliance Officer
Chief Loan Officer
Servicemembers Civil Relief Act
FDIC Guidance for Managing Third-Party Risk
Interagency Guidance on Mortgage Servicing Practices Concerning Military Homeowners with Permanent Change of Station Orders
Glenn Gimble, Senior Policy Analyst, at (202) 898-6865 or firstname.lastname@example.org; or Victoria Pawelski, Senior Policy Analyst, at (202) 898-3571 or email@example.com
FDIC Financial Institution Letters (FILs) may be accessed from the FDIC's Web site at http://www.fdic.gov/news/news/financial/2012/index.html.
To receive FILs electronically, visit http://www.fdic.gov/about/subscriptions/fil.html
Paper copies may be obtained through the FDIC's Public Information Center, 3501 Fairfax Drive, E-1002, Arlington, VA 22226 (1-877-275-3342 or 703-562-2200).