The more I read the MLA, the more confusing it gets.

MLA requires we give the covered borrower a Statement of the MAPR. A creditor may satisfy this requirement by describing the charges the creditor may impose, relating to the consumer credit to calculate the MAPR ( (model language provided in the Rule).

So a numerical value or the total dollar amount of all charges in the MAPR that apply to the extension of the credit is not required.
We don't give both a Reg Z APR and a MAPR.

For open-end credit (not home-secured) we charge an annual plan fee. So in the month we charge the annual fee, we need to calculate an MAPR (including the fee) for that billing cycle. How about late fees? Any late fee imposed in a billing cycle could produce an MAPR in excess of the 36% limit.

Thanks for any reply!

You just have to provide them with the model statement and their payment schedule according to Reg Z. You do not have to provide them with their individual MAPR amount. This was previously required by the rule but now will not be.

From my understanding annual fees do get added in.

Also from our understanding fees or charges imposed for actual unanticipated late payments, default, delinquency, or similar occurrences do not get included in MAPR.

Minion, agree.