Wanted to share some best practices we were made aware of at our last exam:

1. Keep a copy of both the input and output screen when searching on the DMDC or MLA websites.
2. For repossessions, if there is a lag of more than 6 months from the date you did your search on the DMDC and the date you actually repo the vehicle, do another search.
3. Be sure communication of military status is clear across lines of business.(think safe deposit boxes, DDAs, etc.)
4. Be sure your commercial bankers are fully aware the rule applies to them (banker interviews)
5. Be sure you have vetted all third parties you use in any SCRA covered process.
6. Though not required, be sure you have a policy in place.

FDIC examiners

Excellent update.

I'll also try to mention this during my SCRA-MLA webinar next week.

Thank you.