The Department of Defense’s (DoD’s) amendments to the Military Lending Act (MLA) regulations were effective October 3, 2016 (except for credit cards, which became effective October 3, 2017). The Act applies to all credit unions whenever “consumer credit” is extended to a “covered borrower.” The regulations provide safe harbor options to confirm whether a borrower is a covered borrower and contain other complex requirements and prohibitions. For example, credit unions must provide both written and oral disclosures to covered borrowers and must refrain from charging a Military Annual Percentage Rate (MAPR) above 36%.
In preparation for an examination or audit, credit unions should analyze their fees and ancillary products, review and adjust procedures, and work with third-party vendors to ensure compliance. This webinar will cover MLA requirements and mandatory procedures and disclosures. Situations where the MAPR exceeds the 36% limitation will also be addressed.
Note: This webinar will include analysis of the Interpretive Rule issued by the Department of Defense on December 14, 2017.
Recorded January 24, 2018
Attendance certificate provided to self-report CE credits.
- Which products are covered?
- Written and oral disclosure requirements
- Safe harbor methods for determining “covered borrower” status
- MAPR calculation and special issues with credit card accounts
- DoD’s tests and safe harbor provisions for “bona fide and reasonable” credit card fees
- Action items to prepare for an MLA audit or examination
- DoD’s guidance regarding MLA requirements
- TAKE-AWAY TOOLKIT
- MLA FAQs
- Employee training log
- Quiz you can administer to measure staff learning and a separate answer key
WHO SHOULD ATTEND?
This informative session is designed for compliance, audit, lending, and operations staff.
NOTE: All materials are subject to copyright. Transmission, retransmission, or republishing of any webinar to other institutions or those not employed by your financial institution is prohibited. Print materials may be copied for eligible participants only.