Answer:
The key is not when the loan funds. It is when the customer becomes obligated on the note. If the loan was consummated (not necessarily funded) prior to 10/3/16, then no MLA check was needed. But if the loan will consummate on or after 10/3 then an MLA check needs to be performed. But you can't do it retroactively, so if you had some that consummated between 10/3 and today and you didn't do the check, there is not a way to fix that.
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