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#2134881 - 06/19/17 08:04 PM Basic primer on servicemembers needed
Cornfed Turtle Offline
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Joined: Mar 2006
Posts: 1,323
"...Somewhere in Middle Americ...
Yup, that time.....I need to do the MLA audit. I've gone through the rule, the FAQs and our procedures. Now....one of our branches is located near a national guard unit. There are FT active-duty servicemembers that work there and then there are the folks that train there periodically. During my decades in banking, there have been times when those reservists would come into the Bank, usually in a big group, with orders showing that they were headed somewhere. But there are also a number of active-duty servicemembers that are members of the USAF, full-time.

Our procedures state that we are relying on a report from a CRA to determine the applicability of the MLA. I would expect to see a credit report for a regular member of the USAF stationed at our guard unit to show as an active servicemember. Does that sound correct?

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Lending to Servicemembers (SCRA, JWNDAA), War, Terrorism
#2134883 - 06/19/17 08:34 PM Re: Basic primer on servicemembers needed Cornfed Turtle
Reg Warrior Online
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Posts: 214
Anyone on active duty should have a flag/code on their credit report, this includes reservists, guard (etc.) that have been called to active duty.

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#2134990 - 06/20/17 05:51 PM Re: Basic primer on servicemembers needed Reg Warrior
Cornfed Turtle Offline
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Posts: 1,323
"...Somewhere in Middle Americ...
Thanks, RW....I would have expected to see something on the credit report, too.

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#2134995 - 06/20/17 06:05 PM Re: Basic primer on servicemembers needed Cornfed Turtle
MScarn6942 Offline
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Joined: Aug 2015
Posts: 756
Land Lacking in Lakes, IL
Could there be a timing issue where an active-duty person doesn't show as such on a credit report? Like if I got put into active duty today at 9:00 AM and applied for a loan at noon, would it not show?
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#2135002 - 06/20/17 06:36 PM Re: Basic primer on servicemembers needed Cornfed Turtle
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Joined: Jan 2017
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If the paperwork is too new for a flag show on a credit report, your last safe harbor is to go to the MLA website. Having a copy of the enlistment or active duty orders are not a safe harbor under the MLA.

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#2135021 - 06/20/17 07:21 PM Re: Basic primer on servicemembers needed Reg Warrior
Cornfed Turtle Offline
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Joined: Mar 2006
Posts: 1,323
"...Somewhere in Middle Americ...
We went with using the statement on the credit report from a national credit reporting agency. I'm planning on auditing to that procedure.

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