Military Compliance

Quandis Military Search (QMS) enables you to determine if your customer is protected by the Military Lending Act (MLA), or by the Servicemembers Civil Relief Act (SCRA).  MLA and SCRA provide protections for servicemembers and their dependents. If you have a financial relationship with customers, chances are you are impacted by these laws. QMS can provide instant search results, or it can monitor a portfolio of customers and let you know when your customers enter or exit coverage.


SCRA and MLA differ greatly in terms of coverage, timing of coverage, disclosure requirements, and interest rate calculation and caps.

Servicemembers Civil Relief Act

  • Who: servicemembers on pre-service debts when they subsequently become active duty after opening an account.
  • What: caps interest rate charges, including fees, at 6 percent.
  • When: requires disclosures be provided by mortgage servicers on mortgages at 45 days of delinquency.

QMS provides a cost effective, all-in-one verification of active duty military status of an individual with the US Department of Defense (DoD) as defined by the Servicemembers Civil Relief Act of 2003 (SCRA). If your company needs up-to-the-second information on active duty status of your customer, QMS can automate your searches, returning raw data as well as PDFs.

Military Lending Act

  • Who: active duty servicemembers and their dependents at time of origination.
  • What: caps interest and fees at 36 percent MAPR and requires the effective MAPR to be calculated each month for open-ended credit.
  • When: disclosure must occur when the borrower becomes obligated for the transaction, or at the time the account was established.

QMS offers a cost effective, real-time, all-in-one verification of Covered Borrowers with the US Department of Defense as defined by the Military Lending Act (MLA).  Compliance is a requirement for unsecured consumer lines of credit, credit cards, unsecured closed-end loans, and non-purchase-money secured closed-end loans.  If your company needs a real-time process to meet your MLA obligations, Quandis has the solution.

How Clients Are Using QMS

Whether you’re a fintech lender, financial services firm, or a debt collector, QMS can provide a solution to fit your specific use case. Here are some common use cases and how QMS provided a solution.

Product Features

The QMS product suite offers various services. Here are some common use case on how our clients use our services.

Instant Verification

Common Uses:

  • Interactive scenarios such as eligibility forms containing “Click Here” for verification
  • Underwriting when instant scoring is required
  • Single subject verification
  • General “Real-Time” access when latency is not acceptable

Real-Time Searching

The DoD offers the ability to search for service members provided you know their name and social security number or birth date. This search requires that your users manually key in a name and social security number. Upon completion, you will get a PDF document that details the military status of the service member you searched for:

  • Active Duty
  • Discharged
  • Undetermined
  • Not Found

QMS can solve several problems associated with such manual searching:

  1. Save labor by having QMS do in seconds what would take hours for humans to do
  2. No fat-fingering a social security number and believing your customer was Not Found when in fact they are on active duty
  3. Raw results (Text, Excel, or XML) are available for easy updating of your internal systems
  4. Integrate real-time results into your call center or case management system

Get Started For Free

There is no obligation to test our APIs.

API Keys are required for testing. Contact Quandis to obtain a trial API key. Trial API keys are subject to Quandis’ Terms of Service.

Near Real-Time

Common Uses:

  • Multiple subjects are provided in a search request. Think: All parties associated with a foreclosure
  • Multiple names can be generated from a single subject. Think: Permutate
  • Redacted and non-redacted images are required. Think: Image Packages
  • Near real-time response is acceptable

If you require programmatic access from your application:

  • Submit orders real-time as they trigger from your system
  • QMS can deliver product data to an endpoint you define or use the API to pick up product data
  • Order formats support multiple customers which allows reporting based loan or case number
  • All QMS features (Permutations, Image Packages, SSN Lookups, etc.) are supported
  • REST and SOAP along JSON and Xml formats supported

Get Started For Free

API Keys are required for testing. Contact Quandis to obtain a trial API key. Trial API keys are subject to Quandis’ Terms of Service.


Common Uses:

  • Thousands (or more) subjects need to be verified
  • Thousands (or more) images are required. Think: Zip
  • Reporting statistics are required. Think: Scoring
  • Near real-time response is acceptable

QMS offers the ability to upload a data file of names to search. Features include:

  • No need to re-key data; export your customer data to a spreadsheet
  • Receive a spreadsheet of results in raw data, usually in a few minutes after uploading*
  • Optionally, receive individual PDFs containing all the customers searched

QMS can automate this process for you, adding significant value along the way:

  • Pick up a spreadsheet (or other file) from your company’s secure FTP site
  • QMS will inspect, clean and permutate batch data
  • QMS will automate data exchange (submission and pickup) to DOD
  • QMS splits the giant PDF from the DoD batch request into individual documents
  • QMS can overlay the PDFs with your loan or other customer information
  • QMS can push the raw results and PDFs to your internal systems
  • QMS can notify when orders have processed

* This estimate is based on frequent 100,000-row data files requesting data-only without images. Image requests will increase processing times depending on image selections specified.


Common Uses:

  • Manage SCRA status on a population of subjects over time
  • Manage SCRA on multiple portfolios. Think: Foreclosure, REO, Default Servicing
  • Reporting on what subjects have changed. Think: Delta
  • Reporting statistics are required. Think: Scoring

If you need to perform periodic searches of a portfolio of subjects:

  • You upload a spreadsheet of subjects to us, and tell us how often to search DoD
  • On the first day, you will get a report of all subjects and their status
  • On subsequent days, you will get a report of only your subjects that have a changed status
  • The monitoring population can be updated between monitoring cycles by adding or removing subjects
  • Separate monitoring buckets can be setup allowing separate search schedules (eg. daily, monthly, quarterly, etc.)

QMS Additional Features

Name Permutations

A common problem is a customer name in your database may not match the name in the DoD’s database. For example, Jane Smith-Doe in your database might be listed as Jane Smith in the DoD database.  QMS’s name permutation logic will cover your bases, keeping you in compliance.  Using the Jane Smith-Doe example, QMS will submit all of the following to DoD:

  • Jane Smith-Doe
  • Jane Smith
  • Jane Doe
  • Jane Doe-Smith
  • Jane Smith Doe
  • Jane Doe Smith

If any one of those permutations turns out to be on active duty, QMS will flag your customer as being on active duty. Additionally, QMS will return to you the details of each permutation we searched, keeping you as informed as possible and allowing you to stay in compliance. Additional information can be found on our  Name Parsing and Name Permutations page.

PDFs (aka SCRA Certificates)

Most QMS clients have two uses for the service member data returned by DoD:

  1. Use the raw data to update internal databases, driving workflow or other decision points in your processes, and
  2. Imaging the PDF returned (SCRA Certificate) for compliance reasons, should you need to prove your efforts at a later date

With respect to this SCRA Certificate PDF, QMS offers several enhancements:

  • Overlay information on the raw PDF returned by the DoD, including information such as an account or loan number. This allows you to tie the PDF to the correct records internally,
  • Split the giant PDF returned by the DoD batch process into individual PDFs per customer (including overlay)
  • Include the Submission Screenshot of search criteria submitted to DoD as part of the PDF
  • Package PDFs together into a .zip file
  • Transmit the PDF directly to you via secure FTP, or directly into your internal imaging system (individual PDFs or zipped)
  • Retain the PDF on your behalf in the QMS imaging system

Image Packages

Set up multiple versions of SCRA Certificates with Image Packages. This allows for the ability to:

  • Create numerous PDF packages while applying different settings to each one.
  • Eliminate FTE in post-processing by letting QMS take care of the busy work.
  • Render unique packages for internal and external purposes in order to meet compliance.
  • Set up versions with or without Screenshots, Summary Reports, and NPI Redaction by leveraging a host of QMS options.

Social Security Number Lookup

If you don’t have social security numbers for some of your customers, QMS can look up the SSNs automatically prior to submitting the request to the DoD. When performing a SSN lookup, we search public records by name and address.  This often returns more than one possible “hit”. QMS will search each hit returned by the SSN lookup, so you cover all your bases. If any one of those “hits” turns out to be on active duty, QMS will flag your customer as being on active duty. Additionally, QMS will return to you the details of each “hit” we searched, so you can decide if the hit was in fact your customer.

SSN lookup incur an additional charge, but we’re smart about your options:

  • You can tell us to never bother with SSN lookup, thus never incurring an additional charge
  • If SSN lookups are enabled, but you provide us an SSN anyway, we don’t do a lookup so you don’t incur an additional charge
  • If SSN lookups are enabled, but you don’t provide an address needed to perform the SSN lookup, we don’t do a lookup so you don’t incur an additional charge

File Formats, Naming Conventions and Customization

QDS offers standardized formats for all SCRA products. These formats include field details along with file naming conventions. These formats work well for most clients. Should you have more have specialized requirements, we can customize:

  • Request and response formats for real-time searches
  • Batch formats. If you have existing reports, we can consume your formats to save time. We can produce custom reports to match your specs
  • Customize file naming conventions based on your data to confirm to existing standards
    • e.g. Your IT team requires the image name to start with loan number
  • Schema and business rule validation to ensure minimum field requirements
    • e.g. We can implement logic to detect and notify you of problematic data
  • Permutation Logic *
    • e.g. If your clients impose new compliance requirements, we can help

Most customization can occur without additional cost or impacting timelines.

*Permutation logic needs to be assessed on a per requirement basis. We offer several standard permutations features that covers industry compliance requirements.

Of course, we provide a dashboard with detailed search capabilities, so you always have the option of reporting on all or any subset of your customers you wish, on demand.

DMDC Automation

QDS fully automates the data exchange with DMDC ensuring no humans access sensitive data through the entire process. We’ve ensured the key aspects have been covered:

  • Data exchange between Quandis and DMDC is secure, automated and compliant
  • We’ve optimized re-try (or fault tolerance) into our processes to ensure your orders process on time within SLA
  • DMDC accounts are fully managed and comply with DMDC account rules, IP restrictions and file size limits

*All processing is fully automated. There are scenarios when operational support is necessary and our qualified administrators may manually support orders.

QMS Packages and Pricing

QMS features are bundled into packages designed to meet common needs:

  • Verification package: ideal for banks and other organizations that need to verify active duty status in order to drive their internal processes correctly.
  • Compliance package:  ideal for attorneys and other organizations which need to verify active duty status and prove to third parties (auditors, courts, etc.) that they did so with a complete audit trail of screen shots and certificates.
  • Custom packages: for very large volumes, or for organizations that need to mix-and-match QMS features on an à la carte basis.

Verification Package

Basic Professional Enterprise
Monthly Minimum $49.99 $500 $7,500
Suited for Small Company Medium Enterprise Large Enterprise
Searches per Month up to 5,000 5,000 – 150,000 150,000 +
Price per search $0.10 $0.05 $0.01
Monitor price (per borrower per month) $0.03** $0.02** $0.0025**
* SSN Locator searches cost $1.00. Price includes all aliases searched. Monitoring changes cost $1.00 per change.

** Monitoring pricing tier also incurs a $1/status change. If no changes are detected, nothing is charged.

Verification packages are equipped with the following options:

  • Batch search: uses DMDC Batch Search for fastest high volume turn-times
  • Monitoring: provide QMS with a portfolio of names, and we’ll check their status on a recurring basis, notifying you of changes in status.
  • Permutations: leverage standard Name Permutation features to ensure data is scrubbed
  • Imaging Integration: ensure SCRA images are split into individual images and transmitted back into system of record
  • Certificate overlay: layer loan number, etc., on the certificate returned by DoD
  • SSN locator: perform skip trace and search all aliases located *
  • QMS dashboard: view search results, statistics, and certificate images; download data in Excel or CSV format
  • Certificate imaging: images accessible from the QBO Dashboard
  • sFTP Automated Ordering: QMS monitors your sFTP site for orders, and delivers responses
  • API access: submit orders using Quandis API to automate placing of orders on demand
  • Order via drag-and-drop: upload Excel or CSV for any ad-hoc orders
  • Back office integration: ensure SCRA search results are transmitted back into your system of record

Compliance Package

Basic Professional Enterprise
Monthly Minimum $49.99/month $500 $7,500
Suited for Small Company Medium Enterprise Large Enterprise
Searches per Month up to 1,000 1,000 – 50,000 50,000 +
Price per search $0.50 $0.25 $0.15
* SSN Locator searches cost $1.00. Price includes all aliases searched

Compliance packages includes additional options:

  • Advanced permutations: leverage all options available from name permutation feature to search all required name variations
  • Image packages: generate multiple image packages per order to meet internal and external compliance
  • Image redaction: manage all non-public information (such as SSN) displayed on images
  • Group imagesgroup images by party, case, SSN or DOB
  • Search criteria screenshot: append SCRA submission screenshot to SCRA certificate

Monitoring  – Sample Pricing Scenarios

Monitoring pricing is based on Verification Package pricing, and is conducted monthly:

Initial Load Portfolio Size 5,000 100,000 1,000,000
Initial Search per Customer $0.10 $0.05 $0.01
Initial Search Total $500 $5,000 $10,000
Month 1 Actual Status Changes 7 80 1300
Monitoring cost per borrower $0.03 $0.02 $0.0025
Monitoring total $150 $2,000 $2,500
Cost per status change $1 $1 $1
Total for status changes $7 $80 $1,300
Customers Added 400 8,000 80,000
Cost for Customers Added $40 $400 $800
Customers Removed 350 7,000 70,000
Cost for Customers Removed 0 0 0
Total monitoring bill for Month 1 $197 $2,480 $4,600
Month 2 Actual Status Changes 5 120 500
Monitoring cost per borrower $0.03 $0.02 $0.0025
Monitoring total $151.50 $2,020 $2,525
Cost per status change $1 $1 $1
Total for status changes $5 $120 $500
Customers Added 400 8,000 80,000
Cost for Customers Added $40 $400 $800
Customers Removed 350 7,000 70,000
Cost for Customers Removed 0 0 0
Total monitoring bill for Month 2 $196.50 $2,540 $4,825
Month 3 Actual Status Changes 3 90 600
Monitoring cost per borrower $0.03 $0.02 $0.0025
Monitoring total $153 $2,040 $2,550
Cost per status change $1 $1 $1
Total for status changes $3 $90 $600
Customers Added 400 8,000 80,000
Cost for Customers Added $40 $400 $800
Customers Removed 350 7,000 70,000
Cost for Customers Removed 0 0 0
Total monitoring bill for Month 3 $196 $2,530 $3,950

Custom Packages

If you need to mix-and-match our various features, or or you need manage very large volumes, we’re happy to create a custom package for you at a custom price point. Feel free to give us a call @ 949.525.9005 or drop us an email.

The most popular à la carte features to consider are:

  • Excel-based ordering: order directly from Excel and download product and images from Excel
  • Permutations: leverage various options from name permutation feature
  • Image packages: generate multiple image packages per order to meet internal and external compliance
  • Group imagesgroup images by party, case, SSN or DOB
  • Search criteria screenshot: append SCRA submission screenshot to SCRA certificate
  • Image redaction: manage all non-public information (such as SSN) displayed on images
  • Back office integration: ensure SCRA search results are transmitted back into your system of record
  • Imaging system integration: QMS pushes certificate images into your imaging system
  • sFTP Automated Ordering: QMS monitors your sFTP site for orders, and delivers responses

MLA Tier Comparison

 Basic Professional Enterprise Notes
Monthly Minimum $49.99 $500 $7,500
Near-real-time Search $0.20 per search $0.05 per search after first 2,500 searches $0.02 per search after first 150,000 searches Enterprise customers may contact us regarding volume discounts.
Searches per Month 0 – 2500 2500 – 150,000 150,000+
Permutations x x x
Unlimited Volume Licensing $250,000 License to Run Unlimited Volume in your Data Center.
MLA API Access x x x For more on how this interface works, see the MLA API.
MLA Dashboard x x x View Results and Certificate Images, Download to Excel or CSV.
Support Email – up to 2 days Email or Phone – same day Email or Phone – within hour All response times are measured in business days.
Cost Calculator
Searches per month
Cost per month

Geeky Stuff

For the more technically inclined readers, a few extra points about QMS:

  • We offer OpenAPI (see our API): integrate with us directly into your CMS or call center apps
  • Exchanging data via HTTPS or sFTP is cake; other protocols just require a bit of lead time
  • We encrypt data at rest (PGP, TDE) to satisfy the highest security requirements
  • We offer a "pickup model" for those who don't allow inbound transactions
    • e.g. some clients do not want to open their firewalls or simply don't have the infrastructure to allow us to push results to them
  • You can set priorities on batches, and QMS will route through batch or real-time processing accordingly
    • e.g. we'll treat your real-time call center lookups as a top priority, and your monthly batch monitoring as low priority
  • If DoD's website is offline for some reason, we don't lose orders; we stage them in a queue until DoD is back online
  • QMS is completely automated; we don't have Quandis employees touching your data (unless you ask us to research something!)
  • We distribute our servers around the country to ensure we comply with DoD's terms of service
  • We can auto-scale our infrastructure to accommodate volume spikes

Frequently Asked Questions

What information do I need to provide for a search?

Searching is performed on the individual's United States Social Security Number (USSSN) or Date of Birth (DOB) and last name. A search can also be invoked without providing a USSSN. If a USSSN cannot be provided, each search record must contain:

  • First Name
  • Last Name
  • Street Address
  • City
  • State
  • Postal Code

How can QMS prove they submitted our exact data to the DOD?

Some clients request a "screen shot" of the data being submitted to the SCRA website as "proof of submission". There are two problems with this request:

1. Such a screen shot does not constitute proof (i.e. it can be easily fabricated)
2. The "screen shot" is required for human users, but is never actually used by automation

Why a screen shot does not constitute proof

One can easily bring up the DoD website, key in data, and print the page. This does not mean that the user actually clicks on the "Lookup" button. As a result, this "proof" can be easily fabricated.

Why the screen shot is never actually used by automation

"Web pages" are HTML rendered by a browser generally geared for human eyes. It does nice things like prompt people to enter the correct data fields, and provide a Lookup button to tell the browser to transmit data back to the SCRA servers. When a user clicks on the "Lookup" button, the user's browser just transmits the data fields to the SCRA servers.

Quandis' technology just transmits the data fields to the SCRA servers, without ever requesting the HTML page that prompts users to enter data fields. Not only is such a page useless to the automation software, requesting the HTML from the SCRA website with every search would actually slow the search down.


Proof of submission means proof that the SCRA website actually received the data Quandis claims to have submitted. The DoD recognizes the need to provide an audit trail in case questions arise about the validity of data in the future. To solve this, DoD provides a ReportID, which is a unique identifier that can be used to reconcile with the DoD at a future date. The ReportID cannot be faked, and is proof both that Quandis submitted the data, and that the SCRA website received the data.

Should a court require that a bank "prove" the DoD listed a service member as active (or not), one must simply contact the DoD with the ReportID, and the DoD can provide the data that was submitted. This is the only fool-proof audit trail.

We have our own XML/JSON formats we use. Can QMS adopt these formats?

Yes. QMS can transform our native QBO formatted data into your organization's format. This is extra effort and will impact the implementation timeline.

Do you offer a Web API?

Yes! We support OpenAPI and SOAP. Orders can be submitted and product data can be accessed through these channels.

We already expose various end points to accept data. Can QMS tap into these endpoints?

Yes. However there are two considerations:

  1. if the current endpoint is not supported by QMS standard protocols then a custom component will need to be built.
  2. Your current endpoint may require a certain XML format to correctly function. When QMS connects to a custom endpoint, we generally transform the data from our standard format to the required endpoint format.

This is extra effort and will impact the implementation timeline.

Is data delivered to QMS in a secure manner?

Yes. Our web based API utilizes HTTPS.  Clients can also transmit batch orders as Excel files with PKI and/or transmitted securely via sFTP. Once on the Quandis network, the request files are processed and individual borrower names and SSNs are stored in a secure SQL Server (with NPI being symmetrically encrypted at rest). Data is transmitted between QMS and the SCRA website over HTTPS.

Are results received from QMS in a secure manner?

Yes, result files are built on the QMS platform, and may be encrypted with PKI and/or transmitted securely via sFTP, FTPS or HTTPS to the client. We can email clients with a secure hyperlink to download the result file. Each search includes a PDF document containing the image of the SCRA website results. Neither this image nor the aggregate results file contain SSNs, though they usually contain borrower information and loan numbers, so continue to be treated securely.

How do I know Quandis employees will not compromise my data?

QMS is a completely automated platform; Quandis employees are not involved with the mechanics of a military search. Quandis system administrators have access to the servers on which the data is processed, and are governed by our Security Policy and Procedures document.

Is the data that you process secure?

The request and result files are encrypted and/or transmitted via secure channels (sFTP, FTPS, or HTTPS). All data within QMS is stored in a secure SQL Server database, with SSNs being encrypted at rest. SQL backups are encrypted, and stored on RAID media in our alternate production data center. RAID media is physically destroyed upon disposal. We do not use tape backups or off-site storage of our backups. All access to RAID media is tightly controlled with a minimum of two-factor authentication, and employees with access are trained in accordance with our Security Policy and Procedures document.

How long do you retain the data?

We retain all data for 90 days by default. However, we can configure on a client-by-client basis different retention periods to comply with client retention policies. We recommend 90 days ensuring we can answer any questions that may arise concerning your data. The monitoring product requires that we retain the data for at least the duration of monitoring.

Is your system scalable? How many searches can you perform?

QMS is cloud hosted and load balanced web and application servers integrate with SQL Server for back end data storage. The limiting factor in volume is the DoD's SCRA website. Our APIs support configurable rate limits and our batch and monitoring products layer on top of DMDC Multiple records submission.

Does Quandis alter data points when performing SCRA verification?

Quandis does not alter data points as long as they conform to DMDC standards. The standards are outlined in the SCRA User Guide (Formatting the Request File). Our Parse and Permutate logic ensures DMDC format compliance. If we must alter data points, we'll flag the subject in our product data and show both the original value and modified values.  Generally speaking, name data points are subject to modification. The original data points are always retained for audit purposes. Clients can optionally enable permutation logic that will create search variations from the original subject where name information is altered. A name permutation inherits the same SSN/DOB from the original.

SCRA: What are the various statuses of a search? What do they mean?

There are 5 possible statues: Active Duty, Discharged, Not Found, Unable To Process and Undetermined.

  • Active Duty - Indicates Active Duty information was located based on SSN or birth date and last name. This is considered a match.
  • Discharged - Indicates Active Duty information was located based on SSN or birth date and last name. The contact shows a discharge date.
  • Not Found - Indicates SCRA has no information based on SSN or birth date and last name. This is considered a no hit.
  • Unable To Process - Indicates an error was encountered when searching SSN or birth date and last name. SCRA generally returns this error when the SSN appears to be in a fictitious pattern such as 999999999 or 111111111. In a very small percentage of cases the SCRA will return this status with what appears to be a valid SSN and last name.
  • Undetermined - Multiple individuals located with the same last name which share the same birth date. Generally speaking, this type of match requires further investigation.

SCRA: What are the various service branches returned by the search?

The DoD system will return one of the following:

  • Army National Guard
  • Army Active Duty
  • Army Temporary
  • Army Reserve
  • Army Unknown
  • Coast Guard Active Duty
  • Coast Guard Reserve
  • Air National Guard
  • Air Force Active Duty
  • Air Force Temporary
  • Air Force Reserve
  • Public Health Services
  • Marine Corps Active Duty
  • Marine Corps Temporary
  • Marine Corps Reserve
  • Marine Corps Unknown
  • Navy Active Duty
  • Navy Temporary
  • Navy Reserve
  • Navy Unknown
  • Nat'l Oceanic & Atmospheric Administration

The branches can optionally be condensed to Air Force, Army, Coast Guard, Marine Corps, Navy, NOAA, Public Health Service for simplicity.

MLA:What is ‘Safe Harbor’?

Safe harbor, as referenced in the MLA, identifies the sources of data which constitute a legally valid check of covered borrower status. Creditors will have a "safe harbor" if they use one of two methods:

  • Using DoD's (DMDC) Database
  • Using a credit report provided by a national consumer reporting agency

Quandis' MLA Search results come directly from the DMDC database, just like the credit reporting agencies results do.

If you use a source of data other than the ones listed above, you will be legally liable for any discrepancies between your results and the DoD's data.

MLA: Does Quandis MLA Search provide ‘safe harbor’?

Yes. Quandis MLA Search performs a real-time search against the DMDC website, which is the "source of truth" for safe harbor results. The key difference between Quandis MLA and a manual search of the DMDC website is Quandis MLA Search results are returned in XML or JSON format, instead of PDF.  We simply parse the PDF returned by DMDC, translating the results into XML or JSON.

MLA: How can I prove my Quandis MLA Search results are ‘safe harbor’?

DMDC provides a "certificate number" that is unique to each search, and can be used to audit the results. Quandis MLA Search extracts this certificate number from the PDF, and includes it in the XML or JSON results. This certificate number provides proof that the search was done against a "safe harbor" data source.

MLA: If my applicant is a spouse of a military active duty member, how do I determine if the spouse is covered?

The DMDC database contains military service members, as well as their dependents -- in short, all covered borrowers. If your applicant is named John Doe, and is married to (or otherwise a dependent of) Jane Doe (an active duty service member), you don't need to search for Jane. If he's covered by the MLA, John Doe will be listed in the DMDC database.

With that said, make sure your names match! John Smith Doe is not the same as John Doe. Quandis' name permutation logic will automate such checks for you.

How does Quandis MLA Search differ from the credit bureau MLA status?

The source of data for both Quandis MLA Search and the credit bureaus is the same - the DMDC database. Note that the credit bureaus do not have a copy of the DMDC database; they use the DMDC API via the DMDC website to retrieve the information. In short, the credit bureaus get their MLA results from the same website Quandis does.

The Quandis MLA Search results are always performed in real time. When you get credit bureau results, the MLA results may be up to 30 days old.

MLA: What is a dependent?

A Dependent is defined as follows:

  1. A spouse;
  2. A child who:
    • Is under age 21;
    • Is under age 23 and is a full-time student and is (or was at the time of the service member’s death) dependent on the member for over one-half of the child’s support; or
    • An unmarried person who:
      • Is placed in the legal custody of the service member by court order for at least 12 consecutive months; or
      • Has either (i) not reached age 21 or (ii) has not reached age 23 and is a full-time student; or (iii) is incapable of self-support because of mental or physical incapacity that occurred while the person was considered a dependent of the service member; and
      • Is dependent on the service member for over one-half of the person’s support; and
      • Resides with the service member unless separated by the necessity of military service or to receive institutional care as a result of disability or incapacity; and
      • Is not otherwise a dependent under any of the other statutory definitions.

MLA: Which loans are covered by Verification?

  • Unsecured consumer lines of credit
  • Credit cards
  • Unsecured closed-end loans
  • Non-purchase-money secured closed-end loans

MLA: What are the loan requirements?

  • Annual Percentage Rate: 36% Limitation
  • Removal of Mandatory Arbitration Clause
  • Removal of Borrowers Waiver of the Right to Legal Recourse
  • Creditors are Prohibited from using the Title of a Vehicle as Security for the Obligation
  • Creditors must allow the borrower to prepay the loan and can't charge a penalty or fee for prepaying all or part of the loan.

MLA: How do I determine who is a ‘covered borrower’?

When you pass Quandis your borrower name and SSN, we will perform a real time search against the DMDC website, returning XML or JSON indicating whether the borrower is a covered borrower.

Other safe harbor options include:

  1. Using the DoD’s Defense Manpower Data Center (DMDC) Database.
  2. Using a credit report provided by a national consumer reporting agency, or a reseller of that credit report, that complies with the Fair Credit Reporting Act (FRCA). Use of alternative or regional credit reporting agencies would not provide a safe harbor.

MLA: What are the penalties and remedies?

Consumers may sue creditors for violations of the new rule, and regulators can also enforce certain penalties if the rules are violated. If a creditor is found to have violated the new rules, the following applies:

  • The loan is void from the inception of the contract
  • If an arbitration agreement was required, it is unenforceable
  • Consumers may recover actual damages of at least $500 for each violation, as well as punitive damages, equitable or declaratory relief, and any other relief provided by law
  • Consumers may recover the costs of the action and their reasonable attorney’s fees
  • Consumers may pursue any other rights or remedies under any other applicable law may be used, including consequential or punitive damages
  • If the creditor knowingly violates the rules, it is a misdemeanor.

MLA: What is the timing of the determination?

The creditor may rely on the information obtained from either method if the creditor obtains it within 30 days prior to the time the consumer initiates the transaction or applies for credit. Quandis' MLA Search results are performed in real time against the DMDC database, so they're always fresh - never stale. Thus, the 30 day 'clock' starts upon receipt of the results from Quandis.

Are CAPTCHAs required?

CAPTCHAs are not required in any aspect of Military Verification. Historically DMDC required CAPTCHA and our solution pattern is outlined here.