Tag: regulatory

On May 11, 2018, financial institutions will be required to perform Customer Due Diligence routines for their legal entity customers, such as a corporation or limited liability company. Here are 3 facts that you should know about this upcoming rule: When validating ownership, financial institutions can accept what customers have provided unless they have a reason to believe otherwise. Some possible trigger events requiring review of beneficial ownership information for existing accounts include: change in ownership and law enforcement warrants or subpoenas. When collecting and updating beneficial ownership information, the financial institution must retain the original and updated information. While financial institutions are required to collect the same basic customer identification program information from business owners that is required from consumer customers, your current policies may not satisfy this new rule. Learn more

The U.S. Senate Banking Committee passed a financial regulatory relief bill (S. 2155) in December 2017 aimed at reducing regulatory burdens on community banks, credit unions and smaller regional banks.  Committee Chairman Senator Mike Crapo (R-ID), sponsored the bill, which has strong bipartisan support, with 23 cosponsors (11 Republicans and 12 Democrats and an independent). The package is likely to be considered by the full Senate in early 2018. The legislation includes two provisions related to consumer credit reporting.  Both were adopted, in part, in reaction to the Equifax data breach. As the bill moves through the legislative process during 2018, it will be important for all participants in the consumer credit ecosystem to be aware of the potential changes in law. One provision deals with fraud alerts and credit freezes for consumers and the other deals with how medical debt is processed for veterans who seek medical treatment outside the VA system. Credit Freezes The bill amends the Fair Credit Reporting Act to provide consumers with the ability to freeze/unfreeze credit files maintained by nationwide credit reporting agencies at no cost, and would extend the time period for initial fraud alerts from 90 days to one year. The credit freeze provisions would also establish a process for parents and guardians to place a freeze on the file of a minor at no cost. The bill would require the nationwide credit reporting agencies to create webpages with information on credit freezes, fraud alerts, active duty alerts and pre-screen opt-outs and these pages would be linked to the FTC’s existing website, www.IdentityTheft.gov.  The credit freeze and minor freeze provisions would preempt State laws and create a national standard. Protections for Veterans The bill also incorporates a provision that would prohibit credit bureaus from including debt for health-care related services that the veteran received through the Department of Veterans Affairs’ Choice Program. The provision would cover debt that the veteran incurred in the previous year, as well as any delinquent debt that was fully paid or settled. The legislation would require a consumer reporting agency to delete medical debt if it receives information from either the veteran or the VA that the debt was incurred through the Veteran’s Choice Program. What’s next The bill now awaits consideration before the full Senate. Senate Majority Leader Mitch McConnell has said that the bill is a “candidate for early consideration” in 2018, but the exact timing of floor debate has yet to be scheduled. Once the package passes the Senate, it will need to be reconciled with the regulatory relief package that was passed by the House last spring.

Cybersecurity has become one of the most significant issues impacting international security and political and economic stability. Our new report, Data Breach Industry Forecast 2018, outlines 5 predictions for the data breach industry in the coming year. Here are 3: The U.S. may experience its first large-scale attack on critical infrastructure, causing disruption for governments, companies and private citizens. Failure to comply with the new EU regulations will result in large penalties for U.S. companies. Attackers will use artificial intelligence to render traditional multifactor authentication methods useless. Read all five predictions>

On June 7, the Consumer Financial Protection Bureau (CFPB) released a new study that found that the ways “credit invisible” consumers establish credit history can differ greatly based on their economic background. The CFPB estimated in its May 2015 study "Data Point: Credit Invisibles" that more than 45 million American consumers are credit invisible, meaning they either have a thin credit file that cannot be scored or no credit history at all. The new study reviewed de-identified credit records on more than one million consumers who became credit visible. It found that consumers in lower-income areas are 240 percent more likely to become credit visible due to negative information, such as a debt in collection. The CFPB noted consumers in higher-income areas become credit visible in a more positive way, with 30 percent more likely to become credit visible by using a credit card and 100 percent more likely to become credit visible by being added as a co-borrower or authorized user on someone else’s account. The study also found that the percentage of consumers transitioning to credit visibility due to student loans more than doubled in the last 10 years. CFPB’s research highlights the need for alternative credit data The new study demonstrates the importance of moving forward with inclusion of new sources of high-quality financial data — like on-time payment data from rent, utility and telecommunications providers — into a consumer’s credit file. Experian recently outlined our beliefs on the issue in comments responding to the CFPB’s Request for Information on Alternative Data. As a brand, we have a long history of using alternative credit data to help lenders make better lending decisions. Extensive research has shown that there is an immense opportunity to facilitate greater access to fair and affordable credit for underserved consumers through the inclusion of on-time telecommunications, utility and rental data in credit files. While these consumers may not have a traditional credit history, many make on-time payments for telephone, rent, cable, power or mobile services. However, this data is not typically being used to enhance traditional credit files held by the nationwide consumer reporting agencies, nor is it being used in most third-party or custom credit scoring models. Further, new advances in financial technology and data analytics through account aggregation platforms are also integral to the credit granting process and can be applied in a manner to broaden access to credit. Experian is currently using account aggregation software to obtain consumer financial account information for authentication and income verification to speed credit decisions, but we are looking to expand this technology to increase the collection and utilization of alternative data for improving credit decisions by lenders. Policymakers should act to help credit invisible consumers While Experian continues to work with telecommunications and utility companies to facilitate the furnishing of on-time credit data to the nationwide consumer reporting agencies, regulatory barriers continue to exist that deter utility and telecommunications companies from furnishing on-time payment data to credit bureaus. To help address this issue, Congress is currently considering bipartisan legislation (H.R. 435, The Credit Access and Inclusion Act of 2017) that would amend the FCRA to clarify that utility and telecommunication companies can report positive credit data, such as on-time payments, to the nation' s credit reporting bureaus. The legislation has bipartisan support in Congress and Experian encourages lawmakers to move forward with this important initiative that could benefit tens of millions of American consumers. In addition, Experian believes policymakers should more clearly define the term alternative data. In public policy debates, the term "alternative data" is a broad term, often lumping data sources that can or have been proven to meet regulatory standards for accuracy and fairness required by both the Fair Credit Reporting Act and the Equal Credit Opportunity Act with data sources that cannot or have not been proven to meet these standards. In our comment letter, Experian encourages policymakers to clearly differentiate between different types of alternative data and focus the consumer and commercial credit industry on public policy recommendations that will increase the use of those sources of data that have or can be shown to meet legal and societal standards for accuracy, validity, predictability and fairness. More info on Alternative Credit Data More Info on Alternative Financial Services

So many insights and learnings to report after the first full day of 2017 Vision sessions. From the musings shared by tech engineer and pioneer Steve Wozniak, to a panel of technology thought leaders, to countless breakout sessions on a wide array of business topics … here’s a look at our top 10 from the day. A mortgage process for the digital age. At last. In his opening remarks, Experian President of Credit Services Alex Lintner asked the audience to imagine a world when applying for a mortgage simply required a few clicks or swipes. Instead of being sent home to collect a hundred pieces of paper to verify employment, income and assets, a consumer could click on a link and provide a few credentials to verify everything digitally. Finally, lenders can make this a reality, and soon it will be the only way consumers expect to go through the mortgage process. The global and U.S. economies are stable. In fact, they are strong. As Experian Vice President of Analytics Michele Raneri notes, “the fundamentals and technicals look really solid across the countries.” While many were worried a year ago that Brexit would turn the economy upside down, it appears everything is good. Consumer confidence is high. The Dow Jones Index is high. The U.S. unemployment rate is at 4.7%. Home prices are up year-over-year. While there has been a great deal of change in the world – politically and beyond – the economy is holding strong. The rise of the micropreneur. This term is not officially in the dictionary … but it will be. What is it? A micropreneur is a business with 0 to 4 employees bringing in no more than $200k in annual revenue. But the real story is that numbers show microbusiness are improving on many fronts when it comes to contribution to the economy and overall performance compared to other small businesses. Keep an eye on these budding business people. Fraud is running fierce. Synthetic identity losses are estimated in the hundreds of millions annually, with 50% year-over year growth. Criminals are now trying to use credit cleaners to get tradelines removed from used Synthetic IDs. Oh, and it is essential for businesses to ready themselves for “Dark Web” threats. Experts advise to harden your defenses (and play offense) to keep pace with the criminal underground. As soon as you think you’ve protected everything, the criminals will find a gap. The cloud is cool and so are APIs. A panel of thought leaders took to the main stage to discuss the latest trends in tech. Experian Global CIO Barry Libenson said, “The cloud has changed the way we deliver services to our customers and clients, making it seamless and elastic.” Combine that with API, and the goal is to ultimately make all Experian data available to its customers. Experian President of Decision Analytics Steve Platt added, “We are enabling you to tap into what you need, when you need it.” No need to “rip and replace” all your tech. Expect more regulation – and less. A panel of regulatory experts addressed the fast-changing regulatory environment. With the new Trump administration settling in, and calls for change to Dodd-Frank and the Consumer Financial Protection Bureau (CFPB), it’s too soon to tell what will unfold in 2017. CFPB Director Richard Cordray may be making a run for governor of Ohio, so he could be transitioning out sooner than the scheduled close of his July 2018 term. The auto market continues to cruise. Experian’s auto expert, Malinda Zabritski, revealed the latest and greatest stats pertaining to the auto market. A few numbers to blow your mind … U.S. passenger cars and light trucks surpassed 17 million units for the second consecutive year Most new vehicle buyers in the U.S. are 45 years of age or older Crossover and sport utility vehicles remain popular, accounting for 40% of the market in 2016 – this is also driving up finance payments since these vehicles are more expensive. There are signs the auto market is beginning to soften, but interest rates are still low, and leasing is hot. Defining alternative data. As more in the industry discuss the need for alternative data to decision, it often gets labeled as something radical. But in reality, alternative data should be simple. Experian Sr. Director of Government Affairs Liz Oesterle defined it as “getting more financial data in the system that is predicted, validated and can be disputed.” #DeathtoPasswords – could it be a reality? It’s no secret we live in a digital world where we are increasingly relying on apps and websites to manage our lives, but let’s throw out some numbers to quantify the shift. In 2013, the average U.S. consumer had 26 online accounts. By 2015, that number increased to 118 online accounts. By 2020, the average person will have 207 online accounts. When you think about this number, and the passwords associated with these accounts, it is clear a change needs to be made to managing our lives online. Experian Vice President David Britton addressed his session, introducing the concept of creating an “ultimate consumer identity profile,” where multi-source data will be brought together to identify someone. It’s coming, and all of us managing dozens of passwords can’t wait. “The Woz.” I guess you needed to be there, but let’s just say he was honest, opinionated and notes that while he loves tech, he loves it even more when it enables us to live in the “human world.” Too much wonderful content to share, but more to come tomorrow …

In a May 4 speech before the ACA International Conference in Washington, FCC Commissioner Michael O’Rielly criticized the FCC’s past decisions on Telephone Consumer Protection Act (TCPA) and outlined his vision on the direction that the new Commission should head to provide more certainty to businesses. Commissioner O’Rielly noted that prior decisions by the FCC and courts have “expanded the boundaries of TCPA far beyond what I believe Congress intended.” He said that the new leadership at the Commission and a new Bureau head overseeing TCPA, provides the FCC with the opportunity to “undo the misguided and harmful TCPA decisions of the past that exposed legitimate companies to massive legal liability without actually protecting consumers.” O’Rielly laid out three principles that he thought would help to frame discussions and guide the development of replacement rules. First, he said that legitimate businesses need to be able to contact consumers to communicate information that they want, need or expect to receive. This includes relief for informational calls, as well as valid telemarketing calls or texts. Second, Commissioner O’Rielly said that FCC should change the definition of an autodialer so that valid callers can operate in an efficient manner. He went on to say that if FCC develops new rules to clarify revocation of consent, it should do so in a clear and convenient way for consumers, but also does not upend standard best practices of legitimate companies. Third, O’Rielly said that the FCC should focus on actual harms and bad actors, not legitimate companies. While Commissioner O’Rielly’ s comments signal his approach to TCPA reform, it is important to note that FCC action on the issue us unlikely to happen overnight. A rule must be considered by the Commission, which will have to allow for public notice and comment. Experian will continue to monitor regulatory and legislative developments on TCPA.

Investors and financial institutions continue to invest in fintech to help meet the dynamic expectations of consumers who want fast, easy and hassle-free access to new financial products and services. Just last week, in his annual letter to shareholders, JP Morgan Chase CEO Jamie Dimon noted that the bank has invested approximately $600 million “on emerging fintech solutions – which include building and improving digital and mobile services and partnering with fintech companies.” Meanwhile, policymakers in Washington continue to grapple with how to spur responsible innovation and how fintech fits into the existing regulatory paradigm. The Office of the Comptroller of the Currency (OCC) continues to move forward with the development of a special purpose national charter for fintech lenders.  On March 15, the OCC issued a draft supplement to its existing Licensing Manual that describes how the agency “will apply the licensing standards and requirements in its existing regulations and policies to fintech companies applying for a special purpose national bank charter.” The draft manual, which is open for a 30-day public comment period ending April 14, 2017, would prohibit fintech lenders from offering products “with predatory features” or entities that inappropriately mingle banking and commerce. The agency also defended its legal authority to make the move without a new law from Congress or any formal rulemaking process, saying it’s doing nothing more than expanding a longstanding practice. At the same time, a group of House Republicans, led by House Financial Services Committee Chairman Jeb Hensarling (R-Tex.), has asked Comptroller of the Currency Thomas Curry to slow down plans to grant special charters to fintech firms. In the letter, the lawmakers state that OCC should provide “full and fair opportunity” for public comment on standards for granting fintech charters and allow President Trump’s pick for the next comptroller to weigh in. The lawmakers go on to say that if OCC “proceeds in haste” to create new limited-purpose charter for fintech, Congress will examine the agency’s actions and “if appropriate, overturn them.” The issue will likely continue to bubble under the surface as Congress and the Trump Administration tackle larger issues such as tax reform, infrastructure spending and possibly wider financial services reform. However, the fintech charter is a legacy item for Comptroller Curry and he is likely to seek to move this to closure given that his term expires at the end of April (although he would remain in place until President Trump nominates and confirms his replacement).

Experian shares five trends and twists coming over the next 12 months, that could push new boundaries and in many cases improve the customer experience as it pertains to the world of credit and finance.

As 2016 comes to a close, many in the financial services industry are trying to assess the impact the Trump administration and Republican controlled Congress will have on regulatory issues. Answers to these questions may be clearer after President-elect Trump is inaugurated on Jan. 20. However, those in the federal regulatory environment are already exploring oversight and regulation of the FinTech and marketplace lending sector. Warning on alternative credit risk models Inquiries by federal and state policymakers over the past year have centered on how FinTech and marketplace lenders are assessing credit risk. In particular, regulators have asked about how credit models different from traditional credit scoring models and what, if any, new attributes or data are being incorporated into credit risk models for consumers and small businesses. On Dec. 2, Federal Reserve Governor Lael Brainard signaled that policymakers continue to be interested in this area during a wide-ranging speech on the potential opportunities and risks associated with FinTech. In particular, Brainard warned that “While nontraditional data may have the potential to help evaluate consumers who lack credit histories, some data may raise consumer protection concerns” and that nontraditional data “… may not necessarily have a broadly agreed upon or empirically established nexus with creditworthiness and may be correlated with characteristics protected by fair lending laws.” Brainard also suggested that there are transparency concerns with alternative scoring models, saying that “alternative credit scoring methods present new challenges that could raise questions of fairness and transparency” given that consumers may not always understand what data is used utilized and how it impacts a consumer’s ability to access credit at an affordable price. Look for regulators and Congress to continue to focus on the fairness and accuracy of new credit risk models and the data underpinning those models in debates surrounding FinTech and Marketplace lending in 2017. A national charter for FinTech? Earlier this month, the Office of the Comptroller of the Currency (OCC) announced that it was considering the creation of a national charter for FinTech lenders. There has long been speculation that the OCC would offer a national charter for FinTech. Analysts have suggested that the creation of a charter could help increase regulatory oversight of the growing market and also provide additional regulatory certainty for the emerging FinTech industry. The OCC’s proposal would create a special purpose national bank charter for FinTech businesses that are engaged in at least one of three core banking activities: receiving deposits; paying checks; or lending money. The OCC will be developing a formal agency policy for evaluating special purpose bank charters for Fintech companies that will designate the specific criteria that companies applying for a charter will have to meet for approval. OCC has suggested that this will likely focus on safety and soundness; financial inclusion; consumer protection; and community reinvestment. The OCC is collecting comments on the proposed policy through Jan. 15, 2017.  

Regardless of personal political affiliation or opinion, the presidential election is over, and the focus has shifted from debate to the impact the new administration will have on the regulatory landscape for banks. While many questions remain regarding the policy direction of a Trump administration, one thing is near certain: change is on the horizon. While on the campaign trail, Trump took aim at banking regulation: “Dodd-Frank has made it impossible for bankers to function. It makes it very hard for bankers to loan money…for people with businesses to create jobs. And that has to stop.” And in his first post-election interview, Trump outlined named financial industry deregulation to allow “banks to lend again” as a priority. Before Election Day, Experian surveyed members of the financial community about their thoughts on regulatory affairs. An overwhelming majority—85 percent—believed the election outcome would impact the current environment. Most surveyed are also feeling the weight of financial regulations established by the Obama administration in the wake of the severe financial crisis of 2008. Five out of six respondents feel current regulations have placed an undue burden on financial institutions. Three-quarters believe the regulations reduce the availability of credit. And less than half believe the regulations are positive for consumers. According to our survey, complying with Dodd-Frank and other regulations has a financial impact for most, with 76 percent realizing a significant increase in spend since 2008. Personnel and technology spend top the list, with an increase of 78 percent and 76 percent, respectively. Top regulations that require the most resources to ensure compliance: the Dodd-Frank Act (70 percent), Fair Lending Act (55), Bank Secrecy Act/Anti-Money Laundering (47) and Fair Credit Reporting Act (42). Specifically, the Dodd Frank and TILA-RESPA Integrated Disclosure were the two most frequently mentioned regulations requiring additional investment, followed by the Military Lending Act and Bank Secrecy Act/Anti-Money Laundering. What lies ahead? It’s difficult to determine how the Trump administration will tackle banking regulations and policy, but change is in the air.

Congress recently took several actions signaling a growing interest in regulatory issues surrounding the Fintech sector. This growing attention follows a number of recent inquiries by federal and state regulators into the business practices in the industry. Subcommittee takes a deep dive into Fintech and OML regulatory landscape In July, the House Subcommittee on Financial Institutions and Consumer Credit held a hearing entitled Examining the Opportunities and Challenges with Financial Technology (“Fintech”). Witnesses and lawmakers voiced optimism that online marketplace lending can help to expand access to capital for consumers and small businesses, but the hearing also focused on a growing schism as to whether new regulations or changes to the underlying framework is necessary to ensure consumers are protected. Some lawmakers and the witness from the American Banking Association expressed concerns that the Fintech and marketplace lenders may benefit from being outside of the supervisory scope of prudential regulators and the Consumer Financial Protection Bureau (CFPB). Witnesses from the marketplace lending industry argued that they are obligated to meet all of the same regulatory compliance requirements as traditional lenders. Rep. McHenry introduces package of Fintech bills aimed at spurring innovation In addition, Congressman Patrick McHenry (R-NC), a member of the House Republican Leadership team and the Vice Chairman of the House Financial Services Committee, introduced two bills this month aimed at spurring innovation in the Fintech industry. H.R. 5724, the Protecting Consumers’ Access to Credit Act of 2016, would clarify that federal law preempts a loan’s interest rate as valid when made. The bill is in response to the Supreme Court’s recent decision not to hear Madden v Midland, a case in which the Second Circuit court ruled that the National Bank Act does not have a preemptive effect after the national bank has sold or otherwise assigned the loan to another party.  The reading of this law has created uncertainty for Fintech companies and the banks that partner with them. H.R. 5725, the IRS Data Verification Modernization Act of 2016, requires the IRS to automate the Income Verification Express Service process by creating an Application Programming Interface (API). The legislation is aimed at speeding up and improving the automation of the loan application process. In particular, it is aimed at streamlining the process by which lenders gain access to tax transcript data. Currently, lenders may require applicants to fill out IRS form “4506-T,” which gives the lender the right to access a summarized version of their tax transcript as part of the process to confirm certain data points on their application. According to industry reports, this manual process at the IRS takes two to eight days, creating unnecessary delays for Fintech companies and banks that rely on leveraging data and technology to make faster, informed decision for consumer and small business lending Both bills have been referred to the House Financial Services Committee for review.

Experian consultant offers his recap from attending a half-day event hosted at The White House called the “FinTech Summit” largely focused on how government agencies can tap into the innovation, in which new firms are offering small-business owners and consumers faster forms of loans and digital payments. Federal regulators have been studying the industry to determine how it can be regulated while still encouraging innovation.

Whether its new regulations and enforcement actions from the Consumer Financial Protection Bureau or emerging legislation in Congress, the public policy environment for consumer and commercial credit is dynamic and increasingly complex. If you are interested to learn more about how to navigate an increasingly choppy regulatory environment, consider joining a breakout session at Experian’s Vision 2016 Conference that I will be moderating. I’ll be joined by several experts and practitioners, including: John Bottega, Enterprise Data Management Conor French, Funding Circle Troy Dennis, TD Bank Don Taylor, President, Automated Collection Services During our session, you’ll learn about some of the most trying regulatory issues confronting the consumer and commercial credit ecosystem. Most importantly, the session will look at how to turn potential challenges into opportunities. This includes learning how to incorporate new alternative data sets into credit scoring models while still ensuring compliance with existing fair lending laws. We’ll also take a deep dive into some of the coming changes to debt collection practices as a result of the CFPB’s highly anticipated rulemaking. Finally, the panel will take a close look at the challenges of online marketplace lenders and some of the mounting regulations facing small business lenders. Learn more about Vision 2016 and how to register for the May conference.

In today’s interconnected world, reaching consumers should be as simple as sending a text or calling their cell phone. However, complying with the Telephone Consumer Protection Act (TCPA) can create an almost insurmountable mountain. While the law has been in place since 1991, TCPA litigation continues to be a considerable source of potential legal and compliance risk for companies communicating with consumers.  There were 1,908 TCPA lawsuits in 2014, an increase of 30 percent over the previous year, and a 231 percent increase in the last four years. Is your business facing challenges in complying with TCPA? Do you want to learn more about the changing and challenging TCPA legal and regulatory framework? Are you looking for best practices on how to win the battle of right party contact? Then you should join us for a breakout session solely focused on TCPA at Experian’s Vision 2016 Conference. The panel features a number of subject matter experts who will be able to provide attendees with a look at this law and some of the best practices to manage risk and ensure compliance. Panelists include: Mary Anne Gorman, Experian Tony Hadley, Experian Tom Gilbertson, Venable LLC   To learn more more about TCPA best practices, check out Experian’s annual Vision Conference in May.

Time to dust off those compliance plans and ensure you are prepared for the new regulations, specifically surrounding the Military Lending Act (MLA). Last July, the Department of Defense (DOD) published a Final Rule to amend its regulation implementing the Military Lending Act, significantly expanding the scope of the existing protections. The new, beefed-up version encompasses new types of creditors and credit products, including credit cards. While the DOD was responsible for implementing the rule, enforcement will be led by the Consumer Financial Protection Bureau (CFPB). The new rule became effective on October 1, 2015, and compliance is required by October 3, 2016. Compliance, however, with the rules for credit cards is delayed until October 3, 2017. While there is no formal guidance yet on what federal regulators will look for in reviewing MLA compliance, there are some insights on the law and what’s coming. Why was MLA enacted? It was created to provide service members and their dependents with specific protections. As initially implemented in 2007, the law: Limited the APR (including fees) for covered products to 36 percent; Required military-specific disclosures, and; Prohibited creditors from requiring a service member to submit to arbitration in the event of a dispute. It initially applied to three narrowly-defined “consumer credit” products: Closed-end payday loans; Closed-end auto title loans; and Closed-end tax refund anticipation loans. What are the latest regulations being applied to the original MLA implemented in 2007? The new rule expands the definition of “consumer credit” covered by the regulation to more closely align with the definition of credit in the Truth in Lending Act and Regulation Z. This means MLA now covers a wide range of credit transactions, but it does not apply to residential mortgages and credit secured by personal property, such as vehicle purchase loans. One of the most significant changes is the addition of fees paid “for a credit-related ancillary product sold in connection with the credit transaction.”  Although the MAPR limit is 36 percent, ancillary product fees can add up and — especially for accounts that carry a low balance — can quickly exceed the MAPR limit. The final rule also includes a “safe harbor” from liability for lenders who verify the MLA status of a consumer. Under the new DOD rule, lenders will have to check each credit applicant to confirm that they are not a service member, spouse, or the dependent of a service member, through a nationwide CRA or the DOD’s own database, known as the DMDC. The rule also permits the consumer report to be obtained from a reseller that obtains such a report from a nationwide consumer reporting agency. MLA status for dependents under the age of 18 must be verified directly with the DMDC. Experian will be permitted to gain access to the DMDC data to provide lenders a seamless transaction. In essence, lenders will be able to pull an Experian profile, and MLA status will be flagged. What is happening between now and October 2016, when lenders must be compliant? Experian, along with the other national credit bureaus, have been meeting with the DOD and the DMDC to discuss providing the three national bureaus access to its MLA database. Key parties, such as the Financial Services Roundtable and the American Bankers Association, are also working to ease implementation of the safe harbor check for banks and lenders. The end goal is to enable lenders the ability to instantly verify whether an applicant is covered by MLA by the Oct. 1, 2016 compliance date. --- If you have inquiries about the new Military Lending Act regulations, feel free to email MLA.Support@experian.com or contact your Experian Account Executive directly. Next Article: A check-in on the latest Military Lending Act news