And yet another regulatory deadline is approaching in 2016…the final rule that amends existing Part 232 implementing the Military Lending Act has a mandatory compliance date of October 3, 2016. I know you may be thinking, October is still a long way away; we will worry about that one later. Not so fast Batman, another deadline relating to this regulatory change occurs this month, in fact only 5 calendar days from today – February 15, 2016!
In order to achieve a safe harbor (who doesn’t love a safe harbor?) under the new regulatory provisions of the Military Lending Act, a bank may utilize two methods for determining a “covered borrower”:
- The Department of Defense database, or
- A consumer report obtained from a consumer reporting agency.
The first method requires the financial institution to verify the military status of the applicant or dependents by entering the last name, social security number, and date of birth of the borrower into the Department of Defense database known as Defense Manpower Data Center (DMDC). The database is available by accessing: https://mla.dmdc.osd.mil. You may get multiple warnings from your anti-virus software when entering the website as it is locked up like Ft. Knox!
In order to utilize this database to verify an applicant’s status as a covered borrower, a bank must request direct access to the DMDC database by February 15, 2016. This can be done by the bank sending an email to: firstname.lastname@example.org in order to express an interest in having access to the database. If you haven’t already, we encourage all of you to take the opportunity to send a quick email as your bank will definitely have loans impacted by the Military Lending Act.
Submitted by Kelly Owsley