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#2076125 - 04/28/16 02:40 PM MLA - section 232.6 mandatory disclosures
okcowgirl Offline
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Joined: Aug 2010
Posts: 102
Oklahoma
Section 232.6 of the Military Lending Act states we must provide mandatory loan disclosures to a covered borrower:

1. A statement of the MAPR applicable to the extension of consumer credit
2. Any disclosure required by Reg Z
3. A clear description of the payment obligation

If we have a loan with several covered borrowers, do we give the disclosures 1 and 2 above to all obligated on the loan or do we give only to the primary applicant?

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Lending to Servicemembers (SCRA, JWNDAA), War, Terrorism
#2078270 - 05/11/16 11:20 PM Re: MLA - section 232.6 mandatory disclosures okcowgirl
Andy_Z Offline
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Andy_Z
Joined: Oct 2000
Posts: 27,752
On the Net
It would be logical to assume that following Reg Z the disclosures need not go to each consumer, but I don't recall the MLA defining this. Hopefully it will be clarified in the upcoming guidance document.
_________________________
AndyZ CRCM
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#2079312 - 05/19/16 02:16 PM Re: MLA - section 232.6 mandatory disclosures okcowgirl
okcowgirl Offline
100 Club
Joined: Aug 2010
Posts: 102
Oklahoma
Andy,
Thank you for responding.

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