The DOD will have the records of the dependents. Pay is based on how many dependents you have and the DOD will have to have their name, DOB, SSN, etc. So if the DOD has that info, then it will be available on the credit report and the MLA website.
Again, our responsibility is to use on the of the two methods for safe harbor. If it's not there, due to military member omission, DOD mistake, etc, it's not really our problem AS LONG AS you retain the documentation to prove safe harbor.
I am also trying to figure out a process to identify covered dependents. The above appears to mean that the DOD (and eventually the credit bureaus) will have information on a servicemember's dependents, but will this cover applicants who are not servicemembers themselves?
For example, if John Doe applies individually for a covered loan and is a dependent of Jane Doe (assume Jane is an active duty servicemember), would John's credit report show that he is a dependent of Jane's or would only Jane's credit report show that John is a dependent of hers?