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#2097063 - 09/06/16 07:16 PM MLA Disclosure
swiggles Offline
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swiggles
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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.
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Lending to Servicemembers (SCRA, JWNDAA), War, Terrorism
#2097082 - 09/06/16 07:52 PM Re: MLA Disclosure swiggles
CompliantOkie Offline
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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.

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#2097088 - 09/06/16 08:04 PM Re: MLA Disclosure swiggles
RR Becca Offline
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out of the frying pan...
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.
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#2097106 - 09/06/16 08:21 PM Re: MLA Disclosure swiggles
raitchjay Offline
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I *think* i read where LaserPro is keeping it for banks who for who knows what reason would want to keep using it.
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#2097112 - 09/06/16 08:25 PM Re: MLA Disclosure swiggles
CompliantOkie Offline
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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. crazy

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#2097113 - 09/06/16 08:26 PM Re: MLA Disclosure swiggles
raitchjay Offline
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How do you remove it? Are you talking about removing it being automatically checked within a standard product...or somehow actually removed?
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#2097118 - 09/06/16 08:44 PM Re: MLA Disclosure swiggles
swiggles Offline
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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.
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#2097119 - 09/06/16 08:46 PM Re: MLA Disclosure swiggles
raitchjay Offline
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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.
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#2097121 - 09/06/16 08:50 PM Re: MLA Disclosure swiggles
RR Becca Offline
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out of the frying pan...
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.
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#2097122 - 09/06/16 08:52 PM Re: MLA Disclosure swiggles
raitchjay Offline
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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.
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#2097125 - 09/06/16 09:05 PM Re: MLA Disclosure swiggles
swiggles Offline
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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.
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#2097170 - 09/07/16 02:27 PM Re: MLA Disclosure swiggles
RR Becca Offline
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out of the frying pan...
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.
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#2097183 - 09/07/16 02:41 PM Re: MLA Disclosure RR Becca
RR Sarah Offline
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Is 16.2.20 available??? If so, I need to light a couple fires myself.
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#2097187 - 09/07/16 02:50 PM Re: MLA Disclosure swiggles
RR Becca Offline
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RR Becca
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out of the frying pan...
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. crazy
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#2097197 - 09/07/16 03:21 PM Re: MLA Disclosure swiggles
raitchjay Offline
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How can you tell if you're on the most recent version (that includes the latest update)?
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#2097199 - 09/07/16 03:23 PM Re: MLA Disclosure swiggles
raitchjay Offline
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Nevermind...i think i figured it out...i think we're only on 16.2.10.
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#2097201 - 09/07/16 03:27 PM Re: MLA Disclosure raitchjay
RR Sarah Offline
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There is another update coming this month, like maybe 9/16?


Anyone talk to Transunion yet? Is the MLA add-on expensive?
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#2097203 - 09/07/16 03:32 PM Re: MLA Disclosure swiggles
JWills, CRCM Offline
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The Mitten State
I was informed by CBC Innovis that the charge will be 10 cents per consumer, per bureau.
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#2097205 - 09/07/16 03:33 PM Re: MLA Disclosure swiggles
raitchjay Offline
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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.
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#2097211 - 09/07/16 03:42 PM Re: MLA Disclosure raitchjay
RR Sarah Offline
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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.
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#2097213 - 09/07/16 03:44 PM Re: MLA Disclosure RR Sarah
RR Becca Offline
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out of the frying pan...
Originally Posted By RR Sarah
There is another update coming this month, like maybe 9/16?


Where did you find that date? I want to put it on my calendar to start bugging them (IT) the day before.
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#2097214 - 09/07/16 03:48 PM Re: MLA Disclosure swiggles
wanted Offline
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wanted
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United States
Has the MLA replaced the Talent amendment OR does it still apply?

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#2097215 - 09/07/16 03:49 PM Re: MLA Disclosure RR Becca
RR Sarah Offline
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RR Sarah
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Up North
Originally Posted By RR Becca
Originally Posted By RR Sarah
There is another update coming this month, like maybe 9/16?


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


I asked our lead processor. smile

Actually, she has communication from LaserPro that the update will be available on 9/16.
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#2097217 - 09/07/16 03:55 PM Re: MLA Disclosure RR Sarah
raitchjay Offline
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Originally Posted By RR Sarah
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.


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?
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#2097219 - 09/07/16 03:56 PM Re: MLA Disclosure swiggles
raitchjay Offline
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Unless the website i'm using is the SCRA website and i just thought it was the DOD website.....
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