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#2101071 - 09/29/16 07:27 PM Is Everone Good to Go?
TryingtoComply Offline
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I'm being told by our Note Department Manager that we not be ready to do a loan covered by MLA for several weeks. The release from D+H (LaserPro) didn't come out until 9/16 and we can't get it scheduled until the first week of October. Of course, we need to do test documents and then draft procedures.

Just wondering how everyone else is doing with preparations for the effective date.
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#2101083 - 09/29/16 08:03 PM Re: Is Everone Good to Go? TryingtoComply
CompliantOkie Offline
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If I were you, I'd be asking why it's taking so long to have the update loaded on your system. Doesn't seem right that they can't get it loaded for 3 weeks. We loaded ours as soon as we could and we're up and running now just working out a few last minute bugs. We'll be 100% running on Monday.

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#2101084 - 09/29/16 08:11 PM Re: Is Everone Good to Go? TryingtoComply
peony Offline
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A lot of our vendors were not ready and some are still not ready. Couple of them are ready but will not let us test until 10/3. Lot loans are coming out of a different loan software than the other loans and we just finally got them to realize that lot loans are subject to MLA and they just released their changes this week but after reviewing them, the disclosure they created is not up to my standards and also they will not be calculating MAPR which means I had to create our own MAPR disclosure to give out and create a MAPR calculator just for those loans.

I thought nothing could ever get worse after what we went through during TRID until now. MLA has been a nightmare for us.

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#2101085 - 09/29/16 08:17 PM Re: Is Everone Good to Go? TryingtoComply
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Amazing. But I feel better knowing that we are not the only ones.
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#2101087 - 09/29/16 08:18 PM Re: Is Everone Good to Go? TryingtoComply
ComplianceMN Offline
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We use LP and we are ready to go. Do a final training with our lending and processing staff today.

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#2101092 - 09/29/16 08:44 PM Re: Is Everone Good to Go? TryingtoComply
Jade'sFire Offline
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Does anyone have any real risk of exceeding the rate cap?

Our main concern was making sure the checks were being completed and that disclosures are given as required. From the MAPR aspect, our testing showed that our product/fee set-up made the MAPR cap a non issue. We are still implementing a monitoring process for MAPR, but it is not like it will be make or break if its not fully functioning on Monday.

I am also trying to keep in mind that there are a lot of open questions on what products could be covered/what the rule intended to cover, so we have documented the reasoning for our decisions on which of our products are subject to MLA. That way, if we are questioned in the future, we at least have something to refer to.
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#2101097 - 09/29/16 08:57 PM Re: Is Everone Good to Go? TryingtoComply
ComplyGuy Offline
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Our vendors are ready to go, we have tested documents and trained lenders on the new procedures. We've been pulling military status checks for the past couple of weeks just to get ready.

Similar to Jade we have some open questions in regards to the rule and the interpretations on some issues, but I'm pretty confident in the majority of our loans we'll be fine.

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#2101116 - 09/30/16 03:04 AM Re: Is Everone Good to Go? TryingtoComply
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We know that our doc fee will throw us over 36% and we are not ready. My solution is to waive the fee for loans to covered borrowers until we can test and train our loan documentation staff. Anyone see an issue with this?

We will still provide the necessary disclosures.
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#2101125 - 09/30/16 11:01 AM Re: Is Everone Good to Go? TryingtoComply
Ski Offline
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we will also waive origination and documentation fees and will use a lending policy that does not include a minimum finance charge (pre-payment penalty) if the 36.00% MAPR is exceeded.

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#2101128 - 09/30/16 12:35 PM Re: Is Everone Good to Go? TryingtoComply
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I just want to make sure I understand what this regulation requires us to do. If the MAPR exceeds 36% we are required to waive the fees anyway, right? Seems like it's just easier to say that we will waive the fees to covered borrowers.
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#2101149 - 09/30/16 02:07 PM Re: Is Everone Good to Go? TryingtoComply
CompliantOkie Offline
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If the MAPR exceeds, 36% you have to change anything to make it not exceed 36%. You can waive fees or change the interest rate. For our micro-lending we will not be able to charge any fees. For some of the other small dollar lending, we can waive 1 fee and keep the other. You just have to make sure the 36% is not exceeded.

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#2101160 - 09/30/16 02:34 PM Re: Is Everone Good to Go? TryingtoComply
RR Becca Offline
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out of the frying pan...
We thought we were good to go. Beware, all LP users - there's an error in the MAPR calculation regarding some fees and you have to load the 16.3.10 release that came out today in order to correct it.

Our IT dept. says it won't be loaded for us until Tuesday night, so I guess we won't be running any of these before Wednesday.
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#2101169 - 09/30/16 02:51 PM Re: Is Everone Good to Go? TryingtoComply
CompliantOkie Offline
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Ugh. Becca that is NOT what I wanted to hear on a Friday morning!!

:Frantically calling our admin:

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#2101171 - 09/30/16 02:54 PM Re: Is Everone Good to Go? TryingtoComply
TryingtoComply Offline
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For goodness sakes! Exactly!

I realize that we are required to calculate the MAPR, but if this is not possible due to software issues can we just document the file to indicate that the product has no fees and that the MAPR does not exceed 36%?
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#2101183 - 09/30/16 03:06 PM Re: Is Everone Good to Go? RR Becca
RR Sarah Offline
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Originally Posted By RR Becca
We thought we were good to go. Beware, all LP users - there's an error in the MAPR calculation regarding some fees and you have to load the 16.3.10 release that came out today in order to correct it.

Our IT dept. says it won't be loaded for us until Tuesday night, so I guess we won't be running any of these before Wednesday.


Do you know if there are specific fees involved or just fees in general?
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#2101191 - 09/30/16 03:14 PM Re: Is Everone Good to Go? TryingtoComply
RR Becca Offline
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out of the frying pan...
I don't know that it's a deal breaker unless you have a bunch of MAPR fees that aren't also PPFCs. Here's what the release notes say:

An issue that caused a fee that is financed into the loan amount and that is not a prepaid finance charge for APR calculations but is a MAPR fee to be double counted in the MAPR calculation has been corrected.
Previously, when the loan included a financed fee that was not a prepaid finance charge but is a MAPR fee, when the MAPR calculation was run, the fee was included in the MAPR calculation twice—once as a MAPR fee and once as a non-MAPR fee, resulting in a MAPR calculation that was a bit low, since the MAPR was being calculated as if the principal amount for the loan was greater by the amount of the additional fee. The lower the loan amount, the more fees increase the APR; and the higher the loan amount, the less fees increase the APR.
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#2101204 - 09/30/16 03:29 PM Re: Is Everone Good to Go? RR Becca
RR Sarah Offline
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Okay thanks. I haven't seen the release notes yet as my co-worker that receives them is out today.
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#2101215 - 09/30/16 03:49 PM Re: Is Everone Good to Go? TryingtoComply
RR Becca Offline
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out of the frying pan...
Do you have a login for the D+H support center? If so you can go download them there.
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#2101217 - 09/30/16 03:50 PM Re: Is Everone Good to Go? RR Becca
RR Sarah Offline
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I do. I'll check it out when I have a minute.
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#2101987 - 10/05/16 09:36 PM Re: Is Everone Good to Go? RR Becca
ccman Offline
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Joined: Sep 2007
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Our LP is giving us the MLA disclosure on ALL consumer loans?
Is there a flag we have not set properly that the loan is not to a covered borrower?
We have very little if any military applicants. We have not gotten .3.10 ver loaded yet.

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#2102061 - 10/06/16 02:35 PM Re: Is Everone Good to Go? ccman
ren Offline
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We noticed that too. but when we entered the status information as no (for not Active) and the date we entered the search. We no longer got the active military disclosure.

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#2102067 - 10/06/16 02:56 PM Re: Is Everone Good to Go? ren
ccman Offline
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Thank you. We will try to correct. IT dept will not have the latest version updated until Friday. thanks all.

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