We just received the information from our vendors on Friday. If we receive an application, discover it is a service member-can we just provide a letter thanking them for their application and letting them know we will have a product soon or do we actually provide an Adverse Action notice?

If they apply, Reg B rules require that you deny it with an AAN, FCRA may apply, unless it is a product you're not offering. This sounds like a plan you offer, just not to the military.

Why are they not eligible?

1002.2(c)((2) The term (AAN) does not include: A refusal to extend credit because the creditor does not offer the type of credit or credit plan requested.

It would be temporary until the products can be developed and tested to comply with the MLA regulations.

We're not creating any new products. We are identifying borrowers and disclosing/tracking when applicable.

Why are you creating new products? (if I may ask)

We are using exist products, nothing new created. The LOS provider added three fields MLA verified, MLA date verified and MAPR. Using these fields we can track applications/loans that qualify for protection.

Rather than turn business away, is it possible to do this manually in the interim? I've no idea your volume or branch distribution. Obviously a smaller bank has an easier time.