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#2090767 - 07/29/16 09:29 PM Re: MLA Covered Borrower Identification Procedures Indy Banker
Sunshine Lady Offline
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I just got into it with no problems. I used Internet Explorer and Mozilla Fire Browsers.
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Lending to Servicemembers (SCRA, JWNDAA), War, Terrorism
#2091204 - 08/02/16 11:05 PM Re: MLA Covered Borrower Identification Procedures CULady
GuitarDude Offline
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So Cal
Originally Posted By CULady
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?
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#2091213 - 08/03/16 11:56 AM Re: MLA Covered Borrower Identification Procedures MBTCompliance
Minion Offline
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Posts: 64
Virginia
The DOD database will have information for both dependents and active duty. So if the credit reporting agencies are pulling directly from the DOD database it will show on the dependents credit report that they are a dependent of an active duty military person. If you were to go put a person's information in the DODs database right now the message below pops up if the person is not active duty or dependent. Hope that helps.

"Based on the information you provided DMDC does not possess information indicating that the individual is either on active duty for more than 30 days or a family member of a service member on active duty
for more than 30 days based on the Status Inquiry Date."

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#2091308 - 08/03/16 03:54 PM Re: MLA Covered Borrower Identification Procedures MBTCompliance
GuitarDude Offline
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So Cal
Thanks Minion!
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#2094852 - 08/23/16 08:15 PM Re: MLA Covered Borrower Identification Procedures MBTCompliance
Beagles22 Offline
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State of confusion
None of the vendors we use for credit reporting are ready yet - and we intend to rely on that for our determination but I am getting worried that they aren't ready and the date is approaching quickly. Has anyone had any feedback that any of the bureau vendors are ready or even the direct reports from the bureaus? We either get no answer at all or that they aren't ready every time we ask....
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#2094859 - 08/23/16 08:25 PM Re: MLA Covered Borrower Identification Procedures MBTCompliance
CULady Offline
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Last I heard Transunion was going to be ready. If they are not, we will have to use the DOD website and key in each applicant. Is it ideal, no, but it will still be possible to continue business as usual and still obtain safe harbor.

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#2094886 - 08/23/16 11:31 PM Re: MLA Covered Borrower Identification Procedures CULady
'Lil Freak! Offline
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Equifax is being utilized by our LOS and they report they have executed the contract with the DoD and are currently working to test production data. Our LOS should have the updates rolled out in another week...we will see....
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#2095384 - 08/25/16 09:21 PM Re: MLA Covered Borrower Identification Procedures MBTCompliance
Jade'sFire Offline
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If you are planning to use the DOD database to check borrower status, how do you plan on retaining documentation of this for the safe harbor purpose?

I think the most conservative process would be to print the input screen showing the identification information entered and then print the certificate page showing the result and place that in the loan file.

Or do you think it is acceptable to retain only a document from your loan origination software that states the date the status was checked, the method used to check, and the result. Example:
Borrower= John Rambo
Method of Verification=MLA Database
Date Verified=10/03/16
Covered Borrower= No
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#2095386 - 08/25/16 09:32 PM Re: MLA Covered Borrower Identification Procedures MBTCompliance
raitchjay Offline
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OK
We will print the screen from the DOD database and scan it with the file. I don't think a reference in the LOS that basically says "we did it" would cut it--at least, that's the way i'm treating it.
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#2095439 - 08/26/16 01:20 PM Re: MLA Covered Borrower Identification Procedures MBTCompliance
ComplyGuy Offline
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Posts: 263
We will be printing the screen from the DOD website showing the status. Agree that the LOS isn't going to be enough.

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#2095516 - 08/26/16 04:01 PM Re: MLA Covered Borrower Identification Procedures Minion
Breeco Offline
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Nebraska
We pulled data on an active member earlier this week and received the message below, so we are wondering if the MLA site is working correctly or not....

"Based on the information you provided DMDC does not possess information indicating that the individual is either on active duty for more than 30 days or a family member of a service member on active duty
for more than 30 days based on the Status Inquiry Date."
Last edited by MiniMee; 08/26/16 04:03 PM.
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#2095584 - 08/26/16 06:16 PM Re: MLA Covered Borrower Identification Procedures Breeco
Newbie06 Offline
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I thought that in order to use the DoD website for verification one had to apply with the DoD and be approved. I did this and was denied but yet I can access the site and get information. Does anyone know if I am confusing this requirement with something else?

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#2095591 - 08/26/16 06:50 PM Re: MLA Covered Borrower Identification Procedures MBTCompliance
bcompliance Offline
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Initially they had you register for access (batch processes maybe?). The website is available publically.
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#2095650 - 08/26/16 10:04 PM Re: MLA Covered Borrower Identification Procedures Breeco
Amandak Offline
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Joined: Jul 2013
Posts: 80
Wisconsin

I just tested a dependent of an active member and it came back with "DMDC does possess information that the individual is either on active duty...". So I am wondering if they do not have everyone updated or you may have entered in incorrect information.

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#2096260 - 08/31/16 02:21 PM Re: MLA Covered Borrower Identification Procedures MBTCompliance
Web Offline
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Posts: 316
I had registered with DOD back in January to do a direct look up by sending an email to them. I don't believe that I received a reply so now I'm wondering do I just need to establish a login ID for department of defense website to do that direct pull or should I have received something from DOD? I'm waiting on our vendor for credit bureau pull capabilities, but if they aren't ready I need to be able to look up direct.

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#2096280 - 08/31/16 03:19 PM Re: MLA Covered Borrower Identification Procedures MBTCompliance
cowgirlsrule Offline
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Arkansas
We were denied also from the DOD. I emailed them a couple of weeks ago and stated that our CRA had not completed processes. I received a response with the User Guide for the website attached. We tested it for our Trust Department that manages rental property on renters they were going to evict. It came back that they were not active servicemembers. My Son-in-law is active duty so I put his SS# in and it replied that he was active duty. I think you only need to set up an account if you are processing batch inquiries. We were told yesterday by our Rep that Transunion was ready. Question: Are you going to check on all your Consumer Non-Residential installment loans. I'm afraid if I train on all the ifs, buts, ands they will forget to do on loans that are covered?

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#2096296 - 08/31/16 04:02 PM Re: MLA Covered Borrower Identification Procedures cowgirlsrule
RR Sarah Offline
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Up North
A couple co-workers went to a user group meeting for our loan processing software provider last week and were told they were pretty confident that the DOD would extend the compliance deadline. Anyone else hear any rumors about an extension? First one I'd heard and I told my staff not to count on an extension.
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#2096301 - 08/31/16 04:17 PM Re: MLA Covered Borrower Identification Procedures MBTCompliance
Adam F Offline
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Posts: 414
VA
The ABA released an update concerning a meeting held with the DoD on 8/2/2016. The memo stated they and other trade associations had emphasized the need for an extension of the compliance date and during that meeting the "DoD indicated it would not be extending the mandatory compliance date."

This is all I have heard on the subject, so my hopes are very slim.
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#2096322 - 08/31/16 05:07 PM Re: MLA Covered Borrower Identification Procedures MBTCompliance
CULady Offline
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Joined: Sep 2007
Posts: 495
WA
I know CUNA requested they push out the mandatory compliance date six months. But I wouldn't count on it.

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#2096347 - 08/31/16 06:01 PM Re: MLA Covered Borrower Identification Procedures MBTCompliance
Matt_B Offline
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A CU, Where Regs Don't Apply
I'm hoping after their clarifications opened up so many new questions that they reconsider, but won't count on it.

We received communication from our Equifax rep that things are up and running and were given instructions on how to access the test environment. Between that and our forms vendor, things are going well, but our loan processing system (with Fiserv) is definitely dragging behind and leaving us very nervous that they won't be ready in time, at least not enough time to even allow a test.
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#2096961 - 09/06/16 01:48 PM Re: MLA Covered Borrower Identification Procedures MBTCompliance
NoJustNo Offline
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Midwest
Although not common, any thoughts on how to handle a new customer that may not have a social security number (yet)?

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