This question comes from our August 8, 2014 CMG meeting. How does the CFPB guidance on Equal Treatment of Same-Sex Married Couples affect SCRA?
ANSWER: The Servicemembers Civil Relief Act (SCRA) is a federal law without any implementing regulations, so it was not addressed in the CFPB’s memo on Equal Treatment of Same-Sex Married Couples. Several provisions of the law refer to “dependents” and the term “dependent” includes the spouse of a servicemember. So issues related to same-sex married couples are a concern when dealing with SCRA.