Now that the DoD proposal is out, we can see that the term "MAPR" will enter the lexicon of retail banking. What's not so obvious is the need to produce, retain, and disclose military versions of all the other key TIL disclosures. If not labeled MFC, how will we present the "total dollar amount of all charges included in the MAPR" as required in the proposed reg? And what good is a payment schedule or TOP from which optional credit insurance premiums or debt cancellation fees have been deducted in compliance with Reg. Z? There's no way to compute the MAPR (or verify it if you are a compliance tester) unless you know these pieces of information and the military version of the Amount Financed to which some of these same fees have been added--also in compliance with Reg. Z.

For the most part, borrowers (and some lenders) do not understand APR. I can't imagine having APR and MAPR in the same loan package and trying to explain why they are different than the interest rate.

I sure hope a lot of bankers take the time to comment on the proposal. I'd hate to see banks shy away from lending to the military because the disclosures are incredibly burdensome.