Our procedures for the MLA credit cards will be as follows:

1. check the MLA status at the time customer applies for a credit card.
2. If "covered borrower" and credit card is approved, will provide the MLA statement disclosure in writing and orally and the credit card agreement/disclosure before the credit card is opened.
3. Our credit card servicer will calculate the MAPR and be sure that it does not exceed 36% and will mail the card and card agreement to customer.

Does this meet the requirements?

Thanks.

Also, currently for the loans, we make sure that the DOD status check is done prior to loan closing and if it is more than 30 days since pulled, we recheck it before closing. For credit cards, when should the status check be done? When will it be considered a violation (getting it after what? approval?)

Thank You.

Anyone?

We pull MLA status on the credit report, so we are pulling it at application. After the account is open, we will also start pulling a monthly report to determine if they are still a covered borrower.
I think as long as it is pulled and disclosures given before or at the time they become obligated on the loan, you will be fine.
Don't forget that you will have to be calculating the MAPR on a monthly basis to ensure they don't go over the 36% in any given statement cycle.