Do we have to check the MLA site on each renewal? We don't run a credit report on renewals.

You might want to start.

Agree with Randy. Any time you have a covered loan that is renewed, you should inquire the database to ensure you obtain the safe harbor.

You could obtain a determination from the DOD website rather than obtain a new credit report. But why would you not want to check your applicant's credit? It may have deteriorated.

The decision was made to not pull a credit report on a straight renewal - we give the exception notice and we just make a copy of the last notice from the old credit report to give the customer. Limiting the number of times a credit report is pulled - as to not ding the customer's score. We have some terms loans that mature every six months. If their credit has deteriorated - we already have the loan. Auditors have been fine with this. We will pull an MLA from the DOD site.

we give the exception notice and we just make a copy of the last notice from the old credit report to give the customer

???? Why?

FDIC said in essence we were using the old credit report - so thus - the copy!
ha