In
an effort to help you understand the new guidelines regarding
the MLA and MAPR requirements we have found the following
information that may be very useful for you and your loan
officers. You can pass this information along to whomever
you think can use it.
For
Credit Unions and other Financial Institutions: We
strongly recommend downloading and reading and having
your loan officers read the following from the NCUA regarding
Complying with Recent Changes to the Military Lending
Act Regulation. This is in order to make sure that you
are following the guidelines of the MLA as per the NCUA
for covered borrowers.
Complying with Recent Changes to the Military Lending Act
Regulation
Interpretive Guidance on Military Lending Act Limitations
on Terms of Consumer Credit Extended to Service Members
and Dependents
Compliance: Should CUs check status of every applicant?
Compliance: When to disclose MAPR to MLA borrowers
Compliance: Does MLA apply if active duty status changes?
Military Lending Act: It Applies to More Products Than You
Think
Federal Register Links for everyone: 7/22/2015
- Limitations on Terms of Consumer Credit Extended to
Service Members
and Dependents
8/26/16
- Military Lending Act Limitations on Terms of Consumer
Credit Extended
to Service Members and Dependents
12/14/2017
- Military Lending Act Limitations on Terms of Consumer
Credit Extended
to Service Members and Dependents
Chart of Required Fees
A FACT Sheet that was derived
from several sources online.
We also recommend having all of your Loan Documents and
loan policy reviewed by a legal source to ensure that they
are compliant with the new MLA regulations Below is the
Military website that you can use to verify a covered member
as per the new regulations. According to the regulations
you cannot just simply ask the borrowers if they are active
military. You must use one of two sources, either the following
website in which case you will need the borrowers Full Name,
Birthdate and SSN, or you can get the information from the
credit bureau reports. We recommend that you document this
verification method on some form that you keep with your
loan document records. For example, you might consider adding
a field: MLA Covered (Yes/No) on your Loan App and if yes,
document the date verified and what source: Credit Bureau
or MLA Website. We would recommend having these fields programmed
into your LOS and a link provided to the website below for
verification purposes.
https://mla.dmdc.osd.mil/
When you put the information into this website you will
automatically get a popup to save a PDF document. You need
to save this document and then open it. We strongly
recommend that you create a folder on your network (IE:
MLA-VERIFIED), that contains these PDF documents that is
secured for only those that need access to them and save
these PDFs in that folder. We recommend that you save these
documents in that folder for future access. You can use
any naming convention that you deem suitable, but we recommend
something like: AppNum-YYYYMMDD-MLA.pdf.
NOTE: All information provided herein is
provided for your informational purposes only and is not
warranted. Compliance
with the MLA is the sole responsibility of your
Institution and its employees.
|