Timing of checks for active duty status

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Question:

Is the Military Lending Act disclosure required on loan renewals? Does it have an expiration date of when it should be pulled? For example, if the loan was prepared in October, but didn't close until February would I need to pull another MLA status report?

Answer:

Are you asking about disclosure or determining the borrower's status. Here is the answer on when you have to determine status.

A creditor’s one-time determination, by using one of the methods provided in 32 CFR 232.5(b)(2), is permitted and deemed to be conclusive with respect to that transaction or account between the creditor and that consumer, so long as the creditor timely creates and maintains a record of the information obtained, solely at the time that

• the consumer initiates the transaction or 30 days prior to that time;
• the consumer applies to establish the account or 30 days prior to that time; or
• the creditor develops or processes a firm offer of credit that includes the status of the consumer as a covered borrower, so long as the consumer responds to that offer no later than 60 days after the creditor provides the offer to the consumer.