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#2167795 - 03/13/18 03:08 PM MLA - Mandatory disclosure - model statement
I luv Giraffes Offline
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Joined: Sep 2008
Posts: 73
If a MLA check was missed on a new credit card application for a line increase that resulted in an approval, does the model statement disclosure (232.6)(a)(1) need to be sent to the borrower after the loan has closed?

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#2167805 - 03/13/18 03:23 PM Re: MLA - Mandatory disclosure - model statement I luv Giraffes
rlcarey Offline
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rlcarey
Joined: Jul 2001
Posts: 83,393
Galveston, TX
a creditor shall provide to the covered borrower the following information before or at the time the borrower becomes obligated on the transaction or establishes an account for the consumer credit

You have an uncorrectable violation.
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#2167994 - 03/14/18 12:14 PM Re: MLA - Mandatory disclosure - model statement I luv Giraffes
bcompliance Offline
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Joined: Sep 2014
Posts: 1,294
Train your staff, document it, and move on.
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CRCM, CAMS

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#2168938 - 03/19/18 03:49 PM Re: MLA - Mandatory disclosure - model statement I luv Giraffes
Andy_Z Offline
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Andy_Z
Joined: Oct 2000
Posts: 27,754
On the Net
Additionally, ensure the loan is compliant with the MLA and if you see any compliance risk for the failure to disclose, I'd be quick to assist the customer in their needs, including a chance to make a new loan and disclosure.
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AndyZ CRCM
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