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#2084235 - 06/20/16 06:15 PM Military Lending Act (MLA)
TaraTLR Offline
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I am doing my reading and research on the new MLA rules going into effect on 10/3/16. I know that the rule will not apply to residential mortgage transactions secured by a dwelling. What about land/lot loans? Any thoughts?

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Lending to Servicemembers (SCRA, JWNDAA), War, Terrorism
#2084248 - 06/20/16 06:36 PM Re: Military Lending Act (MLA) TaraTLR
raitchjay Offline
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Land/lot loans are covered transactions, if for consumer purpose.
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#2084284 - 06/20/16 08:17 PM Re: Military Lending Act (MLA) TaraTLR
Andy_Z Offline
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If it isn't clearly an exception, it's covered.
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#2084608 - 06/22/16 03:52 PM Re: Military Lending Act (MLA) TaraTLR
nbk2yj2 Offline
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Getting into this late, appreciate any help.

Reading under what qualifies as a potential MLA loan:

"Loan is not expressly for the purchase of a car or other personal property and secured by the property being purchased.

Someone please interpret."

Also, what would need to be updated in our LOS systems pertaining to fees if the APR military or not would not exceed 36%

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#2084623 - 06/22/16 04:23 PM Re: Military Lending Act (MLA) TaraTLR
Jade'sFire Offline
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If an active duty servicemember buys a car and gets a loan for the purchase money secured by that car= not a covered loan.
If they want to refinance a loan secured by an car= covered transaction
If they want to take out a loan to buy a motorcycle and secure the loan with their SUV= covered transaction
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#2087427 - 07/11/16 05:50 PM Re: Military Lending Act (MLA) TaraTLR
Jade'sFire Offline
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I need to take another look at the question on the coverage of lot loans.

I have been challenged on my original stance:
"A loan to purchase a lot and to be secured by the lot being purchased is not a covered transaction"

Challenge: A loan to purchase a lot and to be secured by the lot being purchased is a covered transactions because a lot is not considered personal property. Therefore, all lot loans would be covered because they are using the definition of personal property to not include any land/dirt.
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#2087457 - 07/11/16 07:29 PM Re: Military Lending Act (MLA) TaraTLR
raitchjay Offline
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The exemption is for loans secured by a dwelling. It is silent about real estate, which means being secured by real estate (but not a dwelling) doesn't give you an exemption.
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#2087459 - 07/11/16 07:33 PM Re: Military Lending Act (MLA) TaraTLR
raitchjay Offline
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OK
And correct....real estate is not personal property.
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#2087463 - 07/11/16 08:10 PM Re: Military Lending Act (MLA) TaraTLR
cowgirlsrule Offline
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How is everyone identifying their borrower as a Servicemember?

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#2087469 - 07/11/16 08:18 PM Re: Military Lending Act (MLA) TaraTLR
CULady Offline
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Credit report.

Possibly also using the batch check on the MLA website to check our entire membership twice a month to flag accounts. Still working out the details on that one.

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#2087514 - 07/12/16 02:06 PM Re: Military Lending Act (MLA) TaraTLR
ComplyGuy Offline
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We do about 30-40 per month and are just planning on checking the website.

CU, or anyone using the credit report, have you heard anything from the credit agency showing what this will look like on the report and if there will be additional cost?

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#2087533 - 07/12/16 02:38 PM Re: Military Lending Act (MLA) TaraTLR
Andy_Z Offline
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The credit report will get it's info from the database.

CULady, are you checking the MLA database for SCRA purposes? Once a loan is done, knowing the MLA applies serves no purpose unless it's an audit or QC function, so I'm curious.
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#2087558 - 07/12/16 03:43 PM Re: Military Lending Act (MLA) TaraTLR
JWills, CRCM Offline
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Our CRA is not onboard as of yet. They have me down on their list of contacts once they are ready to go. Hopefully soon.
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#2087576 - 07/12/16 04:55 PM Re: Military Lending Act (MLA) TaraTLR
CULady Offline
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We use Transunion and last I heard they said they will be ready to go in September. **fingers crossed** I believe they will have a special section in the alert area where it will indicate if they are a covered borrower or not. I believe there will be an additional cost, but have not heard what that will be.

Andy- We are a credit union, so whenever a new loan is added it will be added under the one account number. If we mark our accounts, we will know from the beginning whether or not MLA will apply. May or may not be helpful. But we can also use it to monitor when they are no longer a covered borrower and their open-end loans will no longer be considered covered and we can stop calculating the MAPR on a monthly basis.

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#2087613 - 07/12/16 07:01 PM Re: Military Lending Act (MLA) TaraTLR
JWills, CRCM Offline
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Good to know CULady. We also use Transunion.
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#2087696 - 07/13/16 03:31 PM Re: Military Lending Act (MLA) TaraTLR
ahkcompliance Offline
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We use Equifax and I have not seen anything if they will provide the code or not. I have sent in emails but not response. No one here seems to know who to contact.

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#2087721 - 07/13/16 04:25 PM Re: Military Lending Act (MLA) TaraTLR
Andy_Z Offline
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CULady, that makes sense especially from the open-end disclosure requirements. I was tunnel visioning on pre-consummation disclosures.

The CRAs are negotiating contracts with the DoD last I heard. It may well be that they won't set pricing to you until this is done.
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AndyZ CRCM
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#2087940 - 07/14/16 01:50 PM Re: Military Lending Act (MLA) ahkcompliance
Minion Offline
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We attended a webinar with Equifax and below is what they said.

Equifax expects to offer Release 1 (System-to-System 5.0 via 5.0 format extension) in Production environments by mid-July 2016, subject to completion of DoD/CRA final contract. Release 1 programming is available in Equifax's Customer Testing environment starting May 11, 2016. Release 2 programming in Customer Test environments will occur in waves within an estimated four to eight weeks after Release 1, in late summer/early fall, followed by Production implementations in stages August through September. Release 2 includes prescreen and account review products, online ACRO 6.0 and platform implementations (Interconnect®, NextGen, Decision Power, and Equifax ePort®).

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#2088408 - 07/15/16 08:50 PM Re: Military Lending Act (MLA) TaraTLR
ahkcompliance Offline
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Thanks Minion! I've sent emails but we have not received any response.

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#2089916 - 07/26/16 03:11 PM Re: Military Lending Act (MLA) Minion
HRH Okie Banker Offline
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Originally Posted By Minion
We attended a webinar with Equifax and below is what they said.

Equifax expects to offer Release 1 (System-to-System 5.0 via 5.0 format extension) in Production environments by mid-July 2016, subject to completion of DoD/CRA final contract. Release 1 programming is available in Equifax's Customer Testing environment starting May 11, 2016. Release 2 programming in Customer Test environments will occur in waves within an estimated four to eight weeks after Release 1, in late summer/early fall, followed by Production implementations in stages August through September. Release 2 includes prescreen and account review products, online ACRO 6.0 and platform implementations (Interconnect®, NextGen, Decision Power, and Equifax ePort®).


Interestingly enough, I just went out and checked Eport and there is nothing on that websight that gives any information, yet, on MLA.
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#2090115 - 07/27/16 03:01 PM Re: Military Lending Act (MLA) TaraTLR
Andy_Z Offline
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Last I knew they were still in contract negotiations, but that was weeks ago. This part of the process is moving slowly, but is obviously important.
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My opinions are not necessarily my employers.
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Rules and Regs minus Relationships equals Resentment and Rebellion. John Maxwell

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#2090149 - 07/27/16 03:54 PM Re: Military Lending Act (MLA) TaraTLR
mtngrrl Offline
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With the effective date October 3, does that mean APPLICATIONS as of October 3 are covered, or loans CLOSED as of October 3? Trying to find it in the text but haven't so far...

And I'm still trying to get my head around checking for military status in the 30 days prior to application...because we're psychic or something...
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#2090152 - 07/27/16 04:03 PM Re: Military Lending Act (MLA) TaraTLR
CULady Offline
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I think this was gone over in another thread, but I believe it will be loans closed on or after 10/3. So loans that were started before that will have to be checked if they will close/funded on or after 10/3. We are hoping the credit bureaus (for us Transunion) will be ready to go prior to that date.

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#2090153 - 07/27/16 04:05 PM Re: Military Lending Act (MLA) CULady
CULady Offline
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This thread is the one I was thinking of. Towards the bottom.

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#2090238 - 07/27/16 07:07 PM Re: Military Lending Act (MLA) mtngrrl
RR Sarah Offline
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Originally Posted By mtngrrl
With the effective date October 3, does that mean APPLICATIONS as of October 3 are covered, or loans CLOSED as of October 3? Trying to find it in the text but haven't so far...

And I'm still trying to get my head around checking for military status in the 30 days prior to application...because we're psychic or something...


Here's how the 30 days prior to application was explained to me and it has to do with the credit report. Say you have a policy that says you can use a credit report obtained within the past 90 days for a new credit request (customer has another loan with you). The new rule says that you can only rely on that credit report if it was obtained within the 30 days prior to the new credit request if it is for a covered borrower.
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