[amcgarvey]

Would it be possible to just give the MLA disclosure model statement to all Credit Card applicants? What would the negatives be of doing such a thing? One of our product vendors is running a little close and we are looking at a potential stopgap measure.

[jholzknecht]

You are only required to deliver the MLA disclosure to a covered borrower on a covered transaction. There does not appear to be a problem with providing the disclosure to all CC applicants. You are just performing unnecessary work. The extra paper provided to the borrower may be confusing.

Your questions leads me to believe that your are concerned that your vendor will not provide you with the ability to determine who is or is not a covered borrower by next week. That confuses me. There is already a free, easy-to-use tool to perform that task for you. You don’t need a vendor. Correct me if I have interpreted your situation incorrectly.

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