The Department of Defense (DOD) has posted a news update on its Military Lending Act (MLA) website informing users of the following:
“Between February 9, 2017 and February 15, 2017 there was a problem with MLA Multiple Record Requests that prevented 149 request files from processing. If you submitted a Multiple Record Request file between 9 and 15 February that failed to process, please submit the file again for processing.”
Under the MLA covered borrowers are afforded special protections. Creditors may conclusively determine covered borrower status under the MLA by using one of the two safe harbor methods, which includes: 1) information obtained from a nationwide consumer reporting agency; or 2) information from the DOD’s MLA database. Creditors may rely on and consider the results obtained from either of these two methods to be accurate.
When utilizing the DOD online database users have the option of performing a Single Record Request or a Multiple Record Request. Creditors using the multiple record request between February 9, 2017 and February 15, 2017 may have experienced a processing error. If your institution submitted a Multiple Record Request between these dates, the DOD recommends that you resubmit the file again for processing.
Compliance Resource, LLC, has heard from clients who have experienced difficulty accessing information via one of the safe harbor methods. As a result, we advise our clients to ensure they are familiar with and have access to both safe harbor methods in the event their primary method for determining covered borrower status is unavailable.
You can access the DOD’s new release here.