Military Lending Act - Are You in Compliance?

In 2006, Congress passed the Military Lending Act (MLA) to help protect active duty service members and their dependents from predatory lending. In 2015, the Department of Defense (DOD) issued a final rule amending the MLA to cover a wider range of credit products impacting traditional creditors like banks and credit unions. The DoD’s Final Rule expanded the scope of the MLA to include the majority of closed or open-ended loans, excluding real estate secured transactions, certain purchase money auto transactions and personal property transactions.

The MLA requires creditors to verify covered borrower status prior to originating or closing certain credit products (and retain the verification for five years). This became effective October 3, 2016. Additional provisions became effective October 3, 2017 and added credit cards under coverage of the MLA (Military Lending Act) regulation. Those in violation of the rule could face steep penalties. MLA Covered Borrower Status helps lenders by providing an indicator of covered borrower status either in a separate segment delivered with a consumer credit report or as a standalone report without a credit report. On December 14, 2017 the Department of Defense (DoD) published some clarification on the Military Lending Act (MLA); an overview of the three amended question and one additional question will be included in the materials.

Is your credit union in compliance with ALL the provisions of the Military Lending Act?

Covered Topics

  • Which service members and dependents are covered by the MLA?
  • What are the required disclosures and when must they be given?
  • Determining covered borrower status and credit card accounts subject to the rule;
  • Fees and charges required to be included in the calculation of the MAPR for credit card accounts;
  • Identifying bona fide and reasonable credit card fees that may be excluded from the MAPR calculation; and
  • Mandatory disclosure requirements and product limitations.
  • Highlights of current exam procedures and practical suggestions for compliance

Who Should Attend?

This informative session is designed for member service representatives, compliance officers, auditors, loan officers, loan assistants, and loan administration staff. This seminar is designed for both those new to lending regulations or more experienced personnel looking for a review of existing requirements.