[jwelch]

Zandon, Joyce Welch, The Bank of Beaver City, CMG Group 1

[jwelch]

Tiz the Law, Joyce Welch, The Bank of Beaver City, Group 1

[jwelch]

Audible, Joyce Welch, The Bank of Beaver City, Group 1

[jwelch]

Still on the historic look back issue…. what if during end of month verification procedures, you find that a loan officer neglected to verify MLA status.
We use the credit report indicator for MLA status; however, on this particular borrower, the DOB was not included on the credit report request giving a “MLA search not performed due to missing required data” message. The loan officer did not take the extra step of verifying MLA status directly with the DOD database.
What would be the best steps to take to correct/fix our mistake? We have yet to identify a covered borrower, so odds are this is not a covered borrower but we need to verify and correct. And obviously provide additional training to the officers on what to do if this occurs again.

[jwelch]

rcooper ~ in your response to Rich on 9/27/16, you indicated that “For those transactions you would not need to identify covered borrowers.”

One of our loan officers is challenging the use of the MLA checklist. They do NOT want to complete the checklist if the loan is for commercial purposes. (The loan would not be subject to MLA)
My question is would it be a “best practice” to always complete the checklist for all loans or to simply complete it ONLY for consumer loans?

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