We recently determined lenders were not conducted the MLA search on covered loans (I know.).
So, I was originally going to have them do the search now, determine if we have any prohibited contract terms or exceeded the 36% MAPR, but if we do the search today, we are only going to get a message that the person was or was not a covered member in the last 30 days. These loans date back several years.

What would you recommend at this point? Just update the process, document the issue and move on?

You cannot use the search site on a retroactive basis without violating the terms of use.

So just document the error and move on?

Not providing the disclosures or exceeding the MAPR voides the loan doesnt it? Wouldn't you need to check to see if you should be collecting payments?

I have never seen the voided loan bit in practice but I dont recall the rule saying anything like RoR hat the customer has to request that the loan be voided.

I'm not following you. I know the loan terms would be void if the borrower was a covered borrower and we failed to give the disclosures but there is no way to go back and find out if they were a covered borrower now, so I am not sure what to do Just chalk it up as an error, notify the Board we have potential outstanding risk I can't quantify and move on?????