Question of the Week

  • QUESTION: Under the Military Lending Act requirements, can we use a covered borrower identification statement to identify covered borrowers?

    ANSWER:  Yes, but you will not be eligible for the Safe Harbor protection.  To be eligible for the Safe Harbor under the MLA, you have to identify covered borrowers using one of the methods listed in the rule.  You must also follow the timing and recordkeeping requirements.  (32 CFR 232.5(a) and (b)).


Question of the Week Archive

Ask An Expert

We want to hear your pressing questions about compliance at your bank. Please fill in the form below. Not all questions will be featured. Your questions will be kept anonymous.