The Office of the Comptroller of the Currency gave a "needs to improve" rating to San Antonio-based USAA Federal Savings Bank regarding its compliance with the Community Reinvestment Act.
The OCC concluded that the distribution of loans by income level of geography for home mortgage loans was "adequate," but it was "poor" for consumer loans. More weight was placed on consumer lending performance due to the bank's business strategy and overall loan volumes. The bank primarily serves the military community and their families.
The regulator found evidence of 546 violations of the Servicemembers Civil Relief Act, or SCRA, including failure to provide SCRA protections to military reservists, wrongful repossessions of vehicles and the filing of inaccurate affidavits in default judgment cases. It also found evidence of 54 violations of the Military Lending Act for using remotely created checks to collect past due amounts from members who were covered borrowers.
In the CRA's performance tests, the bank received an "outstanding" rating on the investment test, a "high satisfactory" on the service test and a "low satisfactory" on the lending test. The bank's previous overall rating was "satisfactory."