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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 on Wednesday, January 24, from 3:00 P.M. to 4:30 P.M., will cover MLA requirements and mandatory procedures and disclosures. Situations where the MAPR exceeds the 36% limitation will also be addressed.
For those participating in this webinar, you can expect to cover:
- 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
After participating in this webinar, attendees will receive: MLA FAQs; employee training log; and a quiz you can administer to measure staff learning and a separate answer key.
This webinar is offered through the League's partnership with the CU Webinar Network. For more information or to register, please click here.