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#2107283 - 11/14/16 11:51 PM
Sample Military Lending Act Policy
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New Poster
Joined: May 2016
Posts: 13
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Hi! I'm new to Compliance and have been tasked with writing a Military Lending Act Policy. Does anyone have a sample they'd be willing to share?
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#2107518 - 11/16/16 02:26 PM
Re: Sample Military Lending Act Policy
smowry80
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10K Club
Joined: Oct 2000
Posts: 27,748
On the Net
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Throwing out there - please do not share copyrighted material if you are not the copyright owner.
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AndyZ CRCM My opinions are not necessarily my employers. R+R-R=R+R Rules and Regs minus Relationships equals Resentment and Rebellion. John Maxwell
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#2107851 - 11/17/16 10:04 PM
Re: Sample Military Lending Act Policy
smowry80
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Platinum Poster
Joined: Feb 2010
Posts: 960
Illinois
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There are other compliance sites, less credible than BOL, that have policy sharing. I've never felt comfortable with that. Although I write our bank's policies, they are the intellectual property of the bank, not me. The other issue is that I'm not sure I trust a stranger to get it right. I never liked group projects in school. MLA isn't the most complex rule. Get the reg and the Q&A from late September and sketch out a policy that fits your bank.
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#2107865 - 11/18/16 12:04 AM
Re: Sample Military Lending Act Policy
smowry80
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Gold Star
Joined: Sep 2007
Posts: 496
WA
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We actually just added MLA portions to our existing loan policies instead of creating a new full blown policy.
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#2107875 - 11/18/16 12:11 PM
Re: Sample Military Lending Act Policy
MyBrainHurts
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10K Club
Joined: Jul 2001
Posts: 83,229
Galveston, TX
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Although I write our bank's policies, they are the intellectual property of the bank, not me. I agree. The Board and Management pay good money for the development of internal policies. Someone in the bank just giving away that intellectual property should probably be on the chopping block. If you need a template, they are available for purchase - even from BOL: https://www.bankersonline.com/bankerstore/index.php?main_page=product_info&products_id=2539
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The opinions expressed here should not be construed to be those of my employer: PPDocs.com
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#2107895 - 11/18/16 02:35 PM
Re: Sample Military Lending Act Policy
CULady
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Gold Star
Joined: Dec 2013
Posts: 425
OOOOOOklahoma
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We actually just added MLA portions to our existing loan policies instead of creating a new full blown policy. This. We don't write a new policy for every regulation. We try to keep the policies to a minimum. We do have formal written procedures and training for MLA though.
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#2107900 - 11/18/16 02:50 PM
Re: Sample Military Lending Act Policy
smowry80
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Gold Star
Joined: Apr 2012
Posts: 369
Yaven IV
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Just a word of advice on writing policies:
Determine what the purpose of the policy is: - Do you need a very general policy that will complement more detailed procedures, or - Does your policy need to stand on its own and have more detail
Once you know your main objective for content: - Keep your audience in mind - Start with a general overview including the background of the rule, effective dates, the rule's purpose ... - Then address the main requirements of the rule that your bank must comply with. (covered product identification, covered borrower identification, disclosure requirements, etc) If your bank is exempt from any requirements, be sure to include the requirement in the policy and state the exemption (don't just leave these out, you will forget why it is not addressed) - You could maybe add a section toward the end that mentions training that your bank provides/schedules or additional procedures that address these requirements in more detail.
Hopefully this helps. I'm not an expert in writing policies, but I thought this might help you get the wheels turning.
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"It's time for the Jedi to end." Luke Skywalker
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#2107905 - 11/18/16 03:07 PM
Re: Sample Military Lending Act Policy
smowry80
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Power Poster
Joined: Oct 2009
Posts: 9,088
OK
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More and more, i don't 'get' the need for policies, unless required by the regulation itself. I came up with very detailed procedures, but a policy for it? No.
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#2107909 - 11/18/16 03:30 PM
Re: Sample Military Lending Act Policy
raitchjay
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Diamond Poster
Joined: Aug 2012
Posts: 1,700
48.934476, -114.343735
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More and more, i don't 'get' the need for policies, unless required by the regulation itself. I came up with very detailed procedures, but a policy for it? No. Same here. We have gobs of procedures for things, but I try to keep policies to a minimum. Some folks think that more policies the better (creating a smoke screen for regulators). I don't subscribe to that theory.
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#2108770 - 11/28/16 07:42 PM
Re: Sample Military Lending Act Policy
smowry80
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Diamond Poster
Joined: Apr 2003
Posts: 1,636
snorkeling in warm, clear wate...
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What everyone else said - my two cents is that policies that aren't required become something to maintain and something to let the examiners hang you with. We added bits into loan policy and wrote procedures.
In the meantime, welcome to BOL!
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CRCM|CAMS
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#2161176 - 01/19/18 09:40 PM
Re: Sample Military Lending Act Policy
smowry80
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Diamond Poster
Joined: Mar 2013
Posts: 1,265
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After reading through this discussion, I assume an MLA Policy is not required by the regulation?? We do have one, but if not required, definitely doesn't need annual Board approval.
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#2161197 - 01/19/18 10:38 PM
Re: Sample Military Lending Act Policy
smowry80
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10K Club
Joined: Oct 2000
Posts: 27,748
On the Net
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Mel, first, you picked up on a thread that was over a year old, but it can still be pertinent. Just wanted to ensure you'd seen that. Personally, I'd combine MLA and SCRA but neither is "required" though they may be expected. If your bank has any issues, it would likely be really expected.
But what I wanted to comment on was the frequency of updates. The MLA was revised, the guidance was just updated, and that could trigger policy updates. That said, one point in doing an annual update is that policies denote the direction the bank is going and when the board reaffirms a policy, they reaffirm the direction. That is a larger purpose than administering to any small change. It's not just to meet new requirements.
_________________________
AndyZ CRCM My opinions are not necessarily my employers. R+R-R=R+R Rules and Regs minus Relationships equals Resentment and Rebellion. John Maxwell
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