Memo
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Date: June 10, 2005
To:ABA Member Banks
RE:Banker Verification of Customer Active Duty Status
In order to better ensure bank compliance with the Servicemembers Civil Relief Act (“SCRA”), I sought a meeting with the Department of Defense (“DoD”) to discuss issues surrounding SCRA. I was assisted in this by the President of the Association of Military Banks of America.
In April 2005, we met with the Director, Office of Legal Policy, DoD and the chief legal assistance officers for each military service. Our discussion lead to a mechanism for banks to verify a customer’s active duty status through DoD’s DefenseManpowerDataCenter (“DMDC”).
In May 2005, we met with DMDC representatives to clarify the process for bank access to this information. DMDC staff members are ready and eager to assist bankers in accessing their database. This process should greatly benefit compliance officers.
This memorandum provides you with background information regarding DMDC’s current access system (“current”), as well as a new system which may be effective as early as July 2005. The current system is a controlled access internet system requiring an official request for access and a password initiated procedure. The future internet system is more public and less complicated to access (“public”). You can easily convert to the public system when it becomes effective.
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Background
DMDC is a military data center that has available for your access information relating to the active duty status of servicemembers. It does not provide information to you regarding the date of separation from active duty, history of active duty service, information regarding Reserve or National Guard service or projected dates of separation from service. No information is available to assist in locating a servicemember.
The DMDC active duty status program depends on computer information generated by each of the military services which is transmitted to DMDC. It is a snapshot of active duty and is updated continuously. The information is best accessed by this internet based system and no status information is available by phone or e-mail. Access to the system by internet is available 24/7 and the response to an internet system request is close to instantaneous. DMDC will accept fax or mail requests, but there is an understandable delay in processing these requests, as compared with the internet.
There is a very slight chance for error and some small delay in the military service providing active duty status information to DMDC. DMDC suggests that if there is a discrepancy between its information regarding active duty status and what you are told by the servicemember or others that you contact DMDC by phone at (703)696-6762 or by fax at (703) 696-4146 so that staff can assist you in seeking clarification.
In addition, the system will not show that a person is on active duty until he or she has processed through his or her first duty station. If you receive notice from a customer that he or she has active duty orders, you will not receive a positive response on the system until the active duty date at the earliest.
Questions have been raised regarding the integrity of the system and compliance with any privacy issues. DMDC representatives indicated that both those issues have been addressed and they are confident that adequate system security and firewalls exist to prevent hacking of the database. Also, the procedure for the current and public system has been reviewed by DMDC and DoD staff and there are no privacy issues that could affect the operation of either system.
Both systems are a free service of the DoD and there is no charge. It is my understanding that obtaining active duty status information from the military services directly involves a fee and is a more complicated process. There is no limit on the number of individual requests that the DMDC can process from anyone requesting information.
Neither the current nor the public system will accept automated batch requests for active duty status. A request must be submitted separately for each individual. DMDC has electronic monitoring of all submissions for adherence to this requirement and for quality control.
Current System
If you are interested in participating in the current system, you need to fax or mail a typed request to participate on your bank’s letterhead to DMDC at 703-696-4156 (fax) or DefenseManpowerDataCenter, Military Verification, 1600 Wilson Boulevard, Suite 400, Arlington, VA22209.
The letter should state that your bank is seeking access to the DMDC Military Verification system in order to comply with the Servicemembers Civil Relief Act. In addition, the letter must state that your bank and your bank’s employees with access to the system “will not use the information for any other reason than Servicemember Civil Relief Act searches.”
In addition, you need to complete a DMDC Military Verification Web Application form which asks for your bank’s name and address, your bank’s fax and phone number, the full name of each employee requesting an account to perform verification, his or her e-mail address, phone number and mother’s maiden name. A DMDC letter discussing the current system and an application form are attached.
After your request has been processed by DMDC, you will receive more information about accessing the system along with a password for use by each employee identified on the above form and having access to the system. Your bank’s request for military verification for every individual subject to your inquiry should contain the individual’s first and last name, SSN and year and month of birth. The internet response from DMDC designated the Military Status Report will identify the individual’s last name, beginning date of service, active duty status and service/agency if he or she is on active duty. If the response does not reflect current active duty status, the response will indicate that based on information furnished the “DMDC does not possess any information indicating that the individual is currently on active duty.”
Public System
DMDC is working toward the elimination of the current system and its replacement by a public access system. There is no definite date for implementation of the public system, but it could be as early as July, 2005. It is likely that both systems will operate together for a transition period. If you participate in the current system, you will receive information regarding the transition. The public system will eliminate the need for an authorization letter, account form identification and the use of passwords and individual access accounts, but otherwise will be identical in terms of content.
Conclusion
The DMDC military verification system can assist you in easily and accurately determining a customer’s active duty status. If you have any questions, please contact .
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