To ensure compliance with the Military Lending Act, we will be checking both the military website and including the verification on the credit report. In regards to the credit report, do we need all three bureaus to verify or is just one bureau acceptable? What is best practice?
Just one bureau is acceptable and will keep the bank under the safe harbor. As the regulation states, "To determine whether a consumer is a covered borrower, a creditor may verify the status of a consumer by using a statement, code, or similar indicator describing that status, if any, contained in a consumer report obtained from a consumer reporting agency that compiles and maintains files on consumers on a nationwide basis[.]" 32 CFR §232.5(b)(2)(ii).
As a best practice, we recommend sticking with the military website unless there are technical difficulties...then, in that case, using one of the credit bureaus as a backup.
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