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#2099939 - 09/22/16 03:11 PM Re: Defense publishing FAQ on MLA regulation Aug. 26. John Burnett
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Thanks Raitch! We'll do the same. It hadn't really crossed my mind because we'll be using the credit report for all our products except our overdraft repayment product. It has no finance charges but is payable in more than 4 installments so it's covered.

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#2099961 - 09/22/16 03:51 PM Re: Defense publishing FAQ on MLA regulation Aug. 26. John Burnett
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#2101006 - 09/29/16 04:13 PM Re: Defense publishing FAQ on MLA regulation Aug. 26. John Burnett
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The ABA Live Briefing was clear that you can run checks on your database to remove no longer covered borrowers. The historic prohibition is to prevent you from checking their initial status after the fact. They said it makes sense to run status checks going forward on products such as checking accounts.

Next question from me: what are you guys doing about loans with apps taken prior to 10/3 that don't close until 10/3 or later because the customer didn't come in and sign the docs? I was just told we have more than a few in a queue that are ready to sign, but the customer hasn't come in yet. Unsecured 12 month term loans structured to stay under the MAPR limits, so I'm not all that worried about the risk. One of our banks is a military bank, so not unreasonable to assume 80% are covered borrowers.
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#2101036 - 09/29/16 05:36 PM Re: Defense publishing FAQ on MLA regulation Aug. 26. HMS Pippii
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"a consumer credit transaction or account for consumer credit consummated or established on or after October 3, 2016."

We're tossing those apps in progress into the mix.

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#2101058 - 09/29/16 06:40 PM Re: Defense publishing FAQ on MLA regulation Aug. 26. John Burnett
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We are "tossing" them in also.

I have read this thread twice and still cannot come to a decision about how the handle negative equity on in-direct loans.
I believe we can include negative equity as part of the purchase price, but some of you made good arguments for not including it.
For those of you that believe an in-direct sale with negative equity is a covered loan, how are you going to enforce compliance of oral and written disclosures on the dealership when the bank does not receive the completed contract until after the deal is done?
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#2101422 - 10/03/16 03:48 PM Re: Defense publishing FAQ on MLA regulation Aug. 26. John Burnett
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That's what we did - everything that hadn't closed on Friday was run through the database and re-documented for closing this week. We had 30+ covered borrowers that popped up.
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