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#2091587 - 08/04/16 04:13 PM MAPR & Statement on Disclosure??
peony Offline
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peony
Joined: Mar 2013
Posts: 250
Trying to wrap my head around this....

Are we required to have the statement on all Reg Z disclosures? (TIL, Loan Estimate & Closing Disclosure) Or can we provide the statement on a separate document to go with the Reg Z disclosures?

Are we required to show the MAPR amount/percentage on the Reg Z disclosures just like we do with interest rate/APR?

Keep seeing inconsistent information and I need some confirmation.

Thanks!!

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#2091816 - 08/05/16 02:21 PM Re: MAPR & Statement on Disclosure?? peony
peony Offline
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peony
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Ok, I think I figured out that we do not have to show the MAPR amount/percentage...

however, I'm still stumped on whether or not if we can give a separate disclosure that only shows MAPR model statement or have to have it on the Reg Z disclosures. The more I read, the more I'm interpreting that we can do it on a separate form.

Am I interpreting it right?

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#2091862 - 08/05/16 03:15 PM Re: MAPR & Statement on Disclosure?? peony
Minion Offline
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Virginia
You can do it on a separate form or incorporate it into your loan document. For our land loans we will be providing the statement on separate document.

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#2091867 - 08/05/16 03:24 PM Re: MAPR & Statement on Disclosure?? peony
peony Offline
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peony
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That's good to know - Our plan is to do a separate form with the MLA statement and the toll-free number for the covered borrower to call for our deposit advance products. We recently ordered a stock of deposit advance product application/disclosure and we were hoping to do a separate form to include the statement and the number to give to covered borrowers until the stock runs out.

One more question, if we add the statement and the toll-free number on our Reg Z disclosures and/or application for all other products (loans, credit cards, etc) across the board (meaning both covered and non-covered borrowers), would that get us in trouble? Should we only provide the statement and number to the covered borrowers??

Last edited by peony; 08/05/16 03:34 PM.
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#2091982 - 08/05/16 06:52 PM Re: MAPR & Statement on Disclosure?? peony
Andy_Z Offline
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I would opt for a separate statement. You don't want to go into the Fed Box and make alterations that change any of the Reg Z requirements/recommended forms. The same goes for the Schumer box on credit cards.

In some cases there are strict requirements of what belongs there and other items do not belong there for fear that it renders something less conspicuous than it was designed to be.
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#2092111 - 08/08/16 02:11 PM Re: MAPR & Statement on Disclosure?? peony
peony Offline
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peony
Joined: Mar 2013
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Do anyone else want to chime in about having the MAPR statement/toll free number on applications for covered products for anyone to see whether or not they are covered borrowers?

Thanks!

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#2098980 - 09/16/16 08:30 PM Toll Free Number on Applications peony
jmd Offline
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We were going to put the toll free number on our applications for consumer loan products. Of course, not all consumer loans are covered, so the MAPR statement would not be applicable for all consumer loans. Is anyone planning on including the toll free number on applications. How are you addressing this?

Thank you
Last edited by jmd; 09/16/16 08:31 PM.
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