I don't see in the final rules if a lender is required to monitor a loan made to a covered borrower for the end of their active duty service. We do have a process in place to monitor end of active duty service for loans covered by SCRA. Is monitoring for end of active duty service required or a best practice? If we are to use the DMDC MLA database the certificate does not include service dates.

Is anyone else going to monitor for end of service for MLA?

If monitoring is required or a best practice we have come up with two options:
1. Monthly check the MLA database or request active duty status from Equifax and
2. Use the DMDC SCRA site to obtain dates of service

Is using the SCRA site allowed to monitor for end of active duty service for MLA? I did find out that the results from the MLA database are not consistent with the SCRA database.

We are hoping to upload our membership once a month (or so) to the MLA site. Once we have information on who is a covered borrower, we will flag the accounts. And if they are no longer covered, we can remove the flags.
I think this is important because with the open ended loans, once they are not a covered borrower, their loan is no longer covered and we will not need to monitor for the MAPR any more. But I have not seen anything saying that it is required.

Hope this helps!

There is no requirement that you monitor, nor that the SM contact you. I think it is only to the banks benefit to have a tickler set up or to check regularly in the even of an early discharge.

We don't know yet what type of pricing the CRAs will have, but their info will come from the DMDC database. If you can check it directly, I would assume it would be less expensive. An advantage I see to the CRA is that an easy print out and you have your record retention. With batch processing that may be more difficult and time consuming.

I think with the batch processing you can request the certificates for any one that is a covered borrower and you would be able to save those files. Not 100% sure on that yet, still have yet to get a test run of it. I keep pressing the lending department to do a test upload of our membership to see what kind of numbers we have and give it a test run to see how it all works before October...