Can someone help me to understand what exactly the MLA is talking about in 232.8(e)(3)?

(e) The creditor uses a check or other method of access to a deposit, savings, or other financial account maintained by the covered borrower, except that, in connection with a consumer credit transaction with an MAPR consistent with §232.4(b), the creditor may:
...
(3) If not otherwise prohibited by applicable law, take a security interest in funds deposited after the extension of credit in an account established in connection with the consumer credit transaction.

So we can only use the funds deposited after the consummation of the loan? And it would only be any share/checking associated with the loan account? We wouldn't be able to use other accounts that they may have within the institution?

Many thanks!

I have the same questions on this. Does anyone have a clear explanation?

I have the exact same question and have not found an answer yet.

I'd like the answer as well.

Anyone...anyone???

I haven't spent much time on this yet but here's my take.

You cannot extend credit to a covered borrower and require the use of a check, withdrawal slip, etc. as access to the account for repayment. You can however take a security interest in funds deposited after the extension of credit in an account established in connection with the consumer credit transaction.

I do not believe this gives you the authority to establish a security interest in an existing account where the funds may be deposited.