We have been testing our software and have discovered that when there is more than one borrower, for example...two borrowers, where one borrower is a servicemember (or dependent) and the other borrower is not, the software still prints a disclosure for each borrower. BUT....in addition to the disclosure, the software spits out a second disclosure for the non-servicemember. On the form, the non-servicemember has three signature options.

• I AM a servicemember.
• I AM a dependent of a servicemember.
• I AM NOT a servicemember or dependent of a servicemember.

And then a warning at the bottom of the form, to complete the form accurately....that knowingly making a false statement on a credit application is a crime.

What in the world is the purpose of this form? We give non-servicemember borrower the MLA disclosure and then have the non-servicemember, say yay or nay that he/she is entitled to the protections?

I know we don't need this form by law. But I am loathe to nixing it without understanding its purpose.

I would be interested in hearing ideas on this. FYI, the software is LaserPro.

We have LaserPro as well. We deleted that form. We cannot rely on a servicemember's word as to whether they are a covered borrower or not so I don't see a need for the form.

That's the Covered Borrower Identification Statement that is the safe-harbor for covered loans right now. I haven't seen anything regarding whether or not it will go away as of 10/3.

I *think* i read where LaserPro is keeping it for banks who for who knows what reason would want to keep using it.

I read that as well raitch so we removed it after Oct 3. Realized my first reply was about as clear as.....well....the MLA reg.

How do you remove it? Are you talking about removing it being automatically checked within a standard product...or somehow actually removed?

Oh....that makes sense! But.....are you going to give all borrowers a disclosure even if one of them according to database or credit report is NOT military or dependent? We can't figure out how to have the software NOT produce the unneeded disclosure. We decided we could simply not print it....but then we're having to rely on someone to remember to do that.

I think it prints in LaserPro only if you tell it that it's a covered borrower....that's my memory of my test transaction anyway.

There's a checkbox you have to select to make it print, but I don't remember if it's at the admin level or the transaction level. I'll see if I can find it and report back.

Is Swiggles talking about the Covered Borrower form (the old thing) or the new MLA disclosure for a covered borrower? If the latter, i think it prints that based on what you tell it on the MLA screen about whether they are a covered borrower or not. If the former, then i think at the transaction level, you have to check the box (or have it default checked in a standard product) in order for it to print.

I am talking about the "Department of Defense Consumer Credit Disclosure" for MLA. I will have the LaserPro manager look at your comments. She, I think, is having difficulty turning it off when just one of the borrowers is not a covered borrower.

I appreciate everyone's comments.

Turns out we're an update behind. I've put in a request to IT to 'rush' getting 16.2.20 loaded so I can check this out, but there's no telling how long it will actually take.

Is 16.2.20 available??? If so, I need to light a couple fires myself.

Website says so. I was hunting the MLA section of the most recent release notes (couldn't find mine offhand) and realized there was a MORE recent set out there.

How can you tell if you're on the most recent version (that includes the latest update)?

Nevermind...i think i figured it out...i think we're only on 16.2.10.

There is another update coming this month, like maybe 9/16?


Anyone talk to Transunion yet? Is the MLA add-on expensive?

I was informed by CBC Innovis that the charge will be 10 cents per consumer, per bureau.

They called (well our reseller called)......i don't think it was super-expensive, but i wasn't really interested in it as we are going to use the DOD website......so i can't recall exactly how much they were asking.

10 cents a customer wouldn't be so bad.

raitchjay, have you tested the DOD website? From what I'm finding, it isn't ready yet. I used a known active service member and I get an affirmative on active duty on the scra database but a generic message from the mla database that basically says they can't tell by the information provided if the person is or is not active duty.

Where did you find that date? I want to put it on my calendar to start bugging them (IT) the day before.

Has the MLA replaced the Talent amendment OR does it still apply?

I asked our lead processor.

Actually, she has communication from LaserPro that the update will be available on 9/16.

I have....and it worked fine (i used it both ways...with someone i knew who was active duty and someone who wasn't).....but the last time i tried was a few weeks ago....now i'm wondering if they've since developed a kink in the system?

Unless the website i'm using is the SCRA website and i just thought it was the DOD website.....

The SCRA site works, the MLA site didn't for me.

This site: https://mla.dmdc.osd.mil/ worked for me.

Okay, I'm feeling a bit sheepish It actually worked for me the first time, I just didn't take the time to read through the whole message. Uffda

Is the Covered Borrower Identification Statement still required under SCRA after the 10/3 MLA effective date?

SCRA is it's own beast, and is still effective. Check out the SCRA/MLA tool on BOL here:

https://www.bankersonline.com/tools/152497

I think y'all may be talking about two different forms.

The Covered borrower ID statement seems to be going away due to the safe harbor check of either the DOD data base or the credit report.

The 'delinquent notice' is what the above tool is referring to and it still applies.

Perfect. Thanks for your help.

Not sure if this question was ever answered here so thought I would take a stab. The "Department of Defense Consumer Credit Disclosure" is required to be provided to the covered borrower. Many times when this is the military member and their spouse I read it as they both would require the notice since one is covered as a member and the other a dependent. Not sure if a separate notice is required.

Also, another question for LP users is what are you doing to evidence receipt? The test form I reviewed had a signature line. I would prefer to remove the signature line and instead have a date referencing when the form was generated and delivered. Has anyone tried modifying this form or determined how they will address?

LP user here - if you find a way to take the signature line off of that form, please share. I have not yet found an option to do so.

Otherwise, our plan is to put that document in the closing stack ahead of the note and procedure will be for the closer to read it and have the borrower(s) sign it before presenting the note.

At this point we had the same plan Becca. I would love to have it generate a delivered date and remove the signature line, but at this point that does not appear to be an option. Do you know if you have multiple covered borrowers (e.g., member and dependent) if it generates two separate notices or one notice with multiple signature lines?

I don't know. The tests I've run were all single borrower.

Our LP system generates a notice for each covered borrower. Then we set it up to print two copies for each, the signature line on the second copy says "Copy"....prompting the closer to give it to the borrower.

Is it correct that each covered borrower (say military member and spouse), must receive the oral disclosure and each must receive his/her own copy of the written disclosure?

Bump

That is the way our document vendor is interpreting it.

Thank you!