One other thing I forgot to mention is that if you are currently using the SCRA website to check military status, you will need to discontinue that because it doesn't have the dependent information.

I don't understand what they are asking in the questionnaire. Any ideas about how to answer these???

1. How many unique customers does your institution currently have?

2. How many applications for credit does your institution receive each day?

--for question 1...is this how many total consumer loans, or how many "covered" loans we currently have on our books.
--for question 2....how many consumer loan applications per day, or how many applications for covered loans?

And if we're not anticipating every doing a "batch" inquiry, then the answer to question 3.a. would be the same answer as for question 2.

a. How many real-time single MLA covered borrower checks does your institution anticipate conducting each day?

Farm Girl, can you tell me where to find more information about the site? I haven't been able to find much of anything. The user manual pulls up a blank one page document, the FAQs are non-existent and my IT support person says the website's security certificate cannot be verified properly.
How do we know what information can be found on the site?

IT needs to click through the certificate message and read about the military security that is used. The security is all explained once you click through.

Thank you, Kathleen. We did click through and see the site. But, the manual and FAQs are blank. Are you saying it is because of something IT needs to do?

swiggles---I am with you, not sure how to answer the questions.

I do not think they are asking about covered borrowers. At this point it would be hard for anyone to know for sure how many there would be since we have not yet had to do major tracking of military members and their dependents.
Ditto for covered loans. I think that question is asking how many loans apps do you have flowing through on any given day.

That's how we answered them anyway.

CULady, how did you answer the question " How many unique customers does your institution currently have?"

I answered them like CULady i think.....unique customers i took to translate (roughly) to how many CIFs we had and i ballparked a guess (what else can you do? every day is different) on how many applications we take a day. For the questions about batch uploads, i indicated it would probably not apply to us.

The number of individual members that we have. I think the question is trying to say that they don't want you counting Joe Smith 4 times if he has 4 accounts.

I've been pondering the number of accounts that they can process per day, per bank if you submit batch files. It's over 12 million total requests per day. Just confirming we all agree there's no requirement to do any type of ongoing scrub of our credit card accounts looking for military personnel and their dependents. I haven't seen anything that appears to require verification after the account has been opened. The questionnaire from DMDC gives the example of checking MLA status for pre-approved offers of credit.

Got our "final" decision from the DOD. They won't let us have access. So, no safe harbour, right? The current way to check isn't a safe harbour in October, right?

I also heard back of the decision and we don't have access either.

I haven't heard anything from Equifax so hopefully there is a code on the credit report we can rely on.

Is anyone using TransUnion as their 3rd Party CRA? If so, how will they be handling this change?

We were not granted access either. My understanding is our options are the MLA website search and via a credit reporting vendor. We use Experian and Transunion. At this point, neither has said anything more than they are looking into it.

We were denied as well, but plan on using the single record request on the DOD website. We do about 1 covered loan per day, so hopefully it won't be a problem.

My info is that 15 direct connection options were approved to the following institutions:

1. ACE Cash Express, Inc.
2. Advance America
3. American Express
4. Bank of America
5. Capital One
6. Citi
7. Discover Financial Services
8. Equifax
9. Experian
10. JPMorgan Chase
11. Sallie Mae Bank
12. TD Bank
13. TransUnion
14. US Bank - pilot
15. Wells Fargo - pilot

The good news is that all 3 major credit bureaus applied and are approved. Hopefully that means they're all working on it. TransUnion is the only one giving us any info but we haven't gotten any decent updates from them other than "testing should be ready at a date to be determined..."

Interesting. I would have thought USAA or Navy FCU would have made the cut.

We use Transunion and they have said they are working on it. The information I have shows the information will be in the Special Messages section where it will say one of the following:

*** MILITARY LENDING ACT SEARCH: NO MATCH FOUND ***
*** MILITARY LENDING ACT SEARCH: MATCH FOUND ***

No word on when though. They did say it will be an add-on product, but pricing is yet to be determined as well.

The three CRAs are in a test environment now, or will be soon. Experian is and the the plan is to bring on one at a time. Once contracts are agreed to the CRAs will be able to get live data. At that point it is assumed the CRAs will be able to discuss pricing with you, their clients.

The CRAs originally were not going to need this access because it was a given they'd get direct access. But the DoD said they couldn't dump the minor dependent data to the CRA and that is why the CRAs are on this list. If a minor dependents info is requested, the CRA won't have it automatically, it will have to query the database too, on an as needed basis.

Now, I hear several banks who are very nervous about how they'll get minor dependent data. Since this is MLA and it's for new loans, I don't see dependent data for minors as critical since in all my years on the loan desk I only recall making 1 loan to a minor, and that was with his dad and at his dads request so the son would develop credit, and it was for the son's car. Am I missing something?

I should add the approved, and denied lenders have supposedly all been notified. We weren't sure if getting on that list for direct access would provide a later benefit or not knowing the DMDC was looking for volume here. It doesn't appear they have any planned use.

I haven't received an email saying either yay or nay (but i assume the answer is nay).