We are at our wits end here.
The topics listed here mainly surround credit cards and LOC's, however, there are other aspects to MFOEL that goes beyond just those two types of accounts (or subaccounts in this case). We are having trouble revising our policies because we can't seem to get a straight answer to some questions. I will post some here now as we are up in there right now on them and hopefully someone can give some insight on them:
1. "Verify credit information such as income and employment" - The commentary on 226.2(a)(20) says we can verify the information but not use it as a condition of granting an advance. What does verify mean? Can we ask for current paystubs? Can we pull new credit?
2. How would we process a new car loan request under the newly defined MFOEL?
3. If the original "plan" was individual and the member wants to establish a joint LOC (and only the LOC), how can we do that if we can't "underwrite" any new advance request?
These are only for starters...we are very confuzzled atm.