A Regulatory & Legislative Advisory for Compliance Professionals
Inside . . .
2 CFPB Uses Bully
Pulpit on Overdraft,
3 ABA Seeks Banker
Feedback on TRID
3 ABA Seeks Clarity
on Mandatory Flood
3 Agencies Approve
Extended Exam Cycle
for Small Banks
4 DFA Limited
4 Report: Whites
Proceeds Meant for
Bank Secrecy Act
5 ABA Challenges
FinCEN Analysis of
5 NYDFS Proposes
ABA WINS EXTRA TIME FOR BANKS TO REQUEST
DIRECT ACCESS TO DOD DATABASE TO FEBRUARY 15
All Banks Urged to Request Access
ABA has won additional time for banks to request access to a key compliance
resource. Following requests from ABA and other groups, the Department of Defense
has extended the deadline to request direct access to the Pentagon’s Defense
Manpower Data Center database until February 15. Directly accessing the database
provides lenders with the quickest way to verify military status for applicants applying
for consumer credit – other than a mortgage or purchase money loan – as required by
the Military Lending Act, which takes effect in October.
The free direct connection provides immediate answers, whereas making batch
queries via the DMDC website can take up to 24 hours. “With the additional time
secured, ABA urges all banks to request direct access,” said ABA’s Nessa Feddis.
“Under the new MLA requirements, all banks are well-advised to verify the military
status of all applicants for covered consumer loans.”
ABA Issues Staff Analysis on Military Status Determinations
In a members-only staff analysis issued on February 4, ABA provided background
information and an FAQ on how banks can determine military or military dependent
status for loan applications as required by recent Military Lending Act regulations.
The staff analysis outlines the three options for making these determinations:
Directly accessing to the Defense Manpower Data Center database;
Querying the DMDC website (which is different from the SCRA website); or
Requesting a credit report.
The first two options are free, while the third will carry an extra charge and does not
cover military dependents under age 18.
ABA has encouraged all banks to request direct access to the DMDC database. While
both direct access and using the website provide immediate individual responses,
direct access will also facilitate immediate responses to batched queries. Batched
queries to the website may require a 24-hour turnaround time.
Banks wishing to request direct access must email dodhra.do
firstname.lastname@example.org by February 15. Bankers who intend to request access
via the above email address may include a subject line stating “Request of [bank
name] for direct connection to the DMDC database to determine military status” and
repeating the request, along with the bank’s full name, address and contact
information in the body of the email. The staff analysis provides further information