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#2074757 - 04/19/16 11:16 PM Best Practices from Recent Exam -SCRA
Tesla Offline
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Joined: Nov 2003
Posts: 3,687
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
It's not that I take life for granted. It's only that the good won't make it. Innocence dies, while Villany Thrives.

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#2075162 - 04/22/16 01:37 PM Re: Best Practices from Recent Exam -SCRA Tesla
Andy_Z Offline
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Joined: Oct 2000
Posts: 27,503
On the Net
Excellent update.

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

Thank you.
My opinions are not necessarily my employers.
Rules and Regs minus Relationships equals Resentment and Rebellion. John Maxwell

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