In a members-only staff analysis issued today, 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 firstname.lastname@example.org by Feb. 15. The staff analysis provides further information about how to apply. Once a bank has applied, it will receive a questionnaire that must be returned by Feb. 19. Due to limited resources, the Pentagon will determine which institutions can receive direct access based on their volume. For more information, contact ABA’s Nessa Feddis.