Can someone please explain what the regulation is saying in 12 CFR 232.5(b)(3)(iii)?

(iii) The creditor develops or processes, with respect to a consumer, a firm offer of credit that (among the criteria used by the creditor for the offer) includes the status of the consumer as a covered borrower, so long as the consumer responds to that offer not later than 60 days after the time that the creditor had provided that offer to the consumer. If the consumer responds to the creditor's offer later than 60 days after the time that the creditor had provided that offer to the consumer, then the creditor may not rely upon its initial determination in developing or processing that offer, and, instead, may act on the consumer's response as if the consumer is initiating the transaction or applying to establish the account (as described in paragraph (b)(3)(i) or (ii) of this section).

Thank you!

Lisa that 32 CFR by the way.

That means if you are sending out pre-screened credit offers and if the recipient responds more than 60 days after the offer is made, the creditor cannot rely on its original determination as to whether the offer was made to a MLA covered borrower.

Thank you! That was my thinking. I am getting push back stating that if we generate a credit report(with the MLA status included) for example on 4/1/2022 and decline them and then they reapply on 5/15/2022 that we can continue to use that credit bureau (with the MLA status). We generally don't pull credit again within 60 days. So my thinking is we need to check DOD for the MLA status and not rely on a previous credit report.

oops sorry 32 CFR is what I meant.