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#2128807 - 05/02/17 05:33 PM Military Lending Act
Anonymous
Unregistered

Is there example anywhere for a loan document with the MAPR for a consumer and a Credit Card?

Or is a statement all that is needed?

Thanks

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#2128894 - 05/02/17 11:07 PM Re: Military Lending Act Anonymous
CULady Offline
Gold Star
Joined: Sep 2007
Posts: 495
WA
Not 100% sure what is being asked, but I'll take a stab at it...

You do not need to disclose the MAPR as a number. You are only required to have the "MAPR statement." on the disclosures. There is model language provided in the regulation. Don't forget about the oral disclosure piece as well.

There are many threads relating to MLA in the "Lending to Servicemembers (SCRA, JWNDAA), War, Terrorism" forum that may be of some help.

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#2128907 - 05/03/17 12:35 PM Re: Military Lending Act Anonymous
Anonymous
Unregistered

Thank you CU!

This statement has to be put on all disclosures or just a customer determined to be a Servicemember?

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#2128917 - 05/03/17 01:06 PM Re: Military Lending Act Anonymous
Adam F Offline
Gold Star
Adam F
Joined: Apr 2013
Posts: 411
VA
§ 232.6 Mandatory loan disclosures.

(a) Required information. With respect to any extension of consumer credit (including any consumer credit originated or extended through the internet) to a covered borrower, a creditor shall provide to the member or dependent the following information clearly and conspicuously before consummation of the consumer credit transaction:

(1) The MAPR applicable to the extension of consumer credit, and the total dollar amount of all charges included in the MAPR.

(2) Any disclosures required by Regulation Z (Truth in Lending), 12 CFR part 226.

(3) A clear description of the payment obligation of the covered borrower, as applicable. A payment schedule provided pursuant to paragraph (a)(2) of this section satisfies this requirement.

(4) A statement that “Federal law provides important protections to regular or reserve members of the Army, Navy, Marine Corps, Air Force, or Coast Guard, serving on active duty under a call or order that does not specify a period of 30 days or fewer, and their dependents. Members of the Armed Forces and their dependents may be able to obtain financial assistance from Army Emergency Relief, Navy and Marine Corps Relief Society, the Air Force Aid Society, or Coast Guard Mutual Aid. Members of the Armed Forces and their dependents may request free legal advice regarding an application for credit from a service legal assistance office or financial counseling from a consumer credit counselor.”
_________________________
It is better to act cautiously beforehand than to suffer afterward.

The answers I give are my opinions. Not legal advice.

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#2128925 - 05/03/17 01:48 PM Re: Military Lending Act Anonymous
#12 Offline
Diamond Poster
Joined: Jun 2005
Posts: 1,338
NSF: that section was revised effective 10/3/16. It now reads as follows:

§ 232.6 Mandatory loan disclosures.

(a) Required information. With respect to any extension of consumer credit (including any consumer credit originated or extended through the internet) to a covered borrower, a creditor shall provide to the covered borrower the following information before or at the time the borrower becomes obligated on the transaction or establishes an account for the consumer credit:

(1) A statement of the MAPR applicable to the extension of consumer credit;

(2) Any disclosure required by Regulation Z, which shall be provided only in accordance with the requirements of Regulation Z that apply to that disclosure; and

(3) A clear description of the payment obligation of the covered borrower, as applicable. A payment schedule (in the case of closed-end credit) or account-opening disclosure (in the case of open-end credit) provided pursuant to paragraph (a)(2) of this section satisfies this requirement.
Last edited by #12; 05/03/17 01:48 PM.
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#2128948 - 05/03/17 03:17 PM Re: Military Lending Act Anonymous
CULady Offline
Gold Star
Joined: Sep 2007
Posts: 495
WA
Anon-

Just those that are a Covered Borrower.

But you can just have one set of disclosures and that's what we chose to do.

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