The additional time will allow more interested stakeholders to indicate whether they would like to connect directly to the DMDC database. In addition, limiting the availability of the best, most efficient option to determine military status of loan applicants will negatively impact smaller and mid-size institutions.įor these reasons, we request an extension on the deadline for indicating interest in the direct connectivity option until March 1, 2016. For the thousands of FIs that provide access to credit to America’s service members and their dependents, the February 1 deadline leaves little time to analyze their options and respond to DMDC in a timely manner. In addition, DMDC has said that direct connections will likely be limited to FIs that will have the largest projected number of inquiries to the database.įIs and other stakeholders were first made aware of the direct access option through DMDC’s first teleconference on MLA database progress held on January 12, 2016. However, DMDC has said that FIs must express their interest in direct access no later than February 1, 2016. One of the more important features of direct connectivity with DMDC is instantaneous data that are critical to making quick credit decisions in today’s lending environment. While FIs may not know with certainty their preference at this time, given uncertainties about the details of the different options, coupled with the need to communicate these options to thousands of FIs impacted by the MLA rule, we believe many FIs may prefer and wish to opt-in to direct connectivity with DMDC because of the advantages noted above. ![]() Additionally, information pertaining to dependents under the age of 18 is accessible. Direct access allows for greater volume of queries to be processed instantaneously versus the 24-hour standard of the website. A fee is likely to be imposed, however, and information pertaining to dependents under the age of 18 is inaccessible. Military status information provided through a CRA.Both individual and batch queries may be submitted to the website, but the website’s response time can be delayed up to 24 hours. Our understanding is that there are three methods to meet the safe harbor: The Final Rule offers a compliance safe harbor for military status determination if the FI queries the DMDC’s database or obtains military status information from one of three national credit reporting agencies (CRAs). Together, our Associations represent thousands of financial institutions (FIs) that proudly provide access to credit for military members and their families.īeginning October 3, 2016, lenders must determine the military status of all of their applicants for many forms of consumer credit. ![]() ![]() The undersigned Associations appreciate the Defense Manpower Data Center’s (DMDC) outreach and commitment to working with us and other stakeholders on issues related to the Military Lending Act (MLA) Database. Acting Under Secretary of Defense (Personnel & Readiness) 3E989,
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