MAPR Disclosure

Okay - so it seems the MAPR disclosure we are to give orally and in writing is just that generic disclosure statement, plus the customer's payment schedule. It does NOT appear that we have to actually provide the MAPR, right? That just seems strange.

So, if that is the case....for those of you using LaserPro - where are you finding this MAPR in order to check it for compliance purposes? Seems like it should print out somewhere (e.g. boarding data sheet or something).

It does print on the Boarding Data..

Thank you! I thought it should be there, but it wasn't on the test loan staff gave me, so I'll have them check on why. Appreciate the fast response!

You have to go into the MAPR Tool setup in Admin and check the box for "Print MLA Information on Boarding Data Sheet."

Thank you for the tip Becca. I'll make sure I check that box. Makes sense to have it included on the boarding data sheet IF the customer is in the office of be read the disclosure.

Can I just say that as a former military dependent, I would find it incredibly condescending for a banker to have to read a disclosure to me like I was illiterate?
Okay. Rant over!!

Ditto. Quite frankly there's a lot of this rule that I would find a bit insulting.

agreed. my boss and i can not understand the need of the oral requirements.

Agreed. This rule could have been written to actually protect service members without limiting their access to good credit products provided by federally insured financial institutions or talking down to them by having to read them a generic statement.

I can understand calculating the MAPR and capping it at 36% but if we don't disclose that actual number to the service member, then telling them it was calculated doesn't give them any actual information at all.

I can hear the conversations now:

Servicemember: where's the credit insurance I asked for?

Bank emp.: We had to remove it because it put the MAPR over 36% and we aren't allowed to do that.

SM: Show me that calculation.

BE: I can't. The DOD said we don't have to so the software doesn't print it out anywhere for you.

It prints on the boarding data sheet & it is also disclosed in the TIL box as the apr.

And when the next release is available 9/16/16, the MAPR Fee and MAPR Information will print on the Loan Request Summary.

I knew it was supposed to print on the Boarding Data Sheet, but that isn't typically a document we give to the customer. I did not know that it would show up on the TIL - we haven't had a chance to do a test run yet. Good to know!

Just for the record, the MAPR and the TILA APR are not necessarily the same number, as there are other items that may or may not be included in the calculation of the MAPR. See 32 CFR 232.4(c)(1).

I understand that the MAPR is located on the Boarding Data sheet within LaserPro, but shouldn't it also be listed on a Military Lending Act Statement that is given to the customer with the projected payments since we do not give out the Boarding Data Sheet? If so, can someone help me locate within LaserPro where it would be located?

Thanks!

mbl - you're adding to a 5 year old thread. Just pointing that out as I think this started when the rules were just changing. You have to disclose a statement of the MAPR, basically what a MAPR is and what it does for the SM, and you have to know what you're charging isn't usurious. I do not know what is on a boarding data sheet but if it's the number, it need not be disclosed, if it's the 232.6(a) and (c) disclosure, a written form the SM can keep is required 232.6(d).

I knew it was a 5 year old post but since it was talking about where it is located at with LaserPro then this would be a good place to start to see if anyone could help me with the disclosures that are needed as the manager of LaserPro does not know where she needs to go to implement the changes that I need.

Currently, we only give Military Lending Act consumers a sheet that states the MAPR disclosure (Department of Defense Consumer Credit Disclosure) and how it cannot be above 36% but we do not give them the actual MAPR or Projected Payment Schedule like the regulation states. The disclosure that states the MAPR and Projected Payment Schedule is what we are having trouble finding for a disclosure that is able to be given to the customer.

I am new to this so I am just learning about the MLA so bear with me as I work through the disclosures that are needed to be given and were we can located them at.

You are not required to disclose the actual MAPR and I'm not aware of anyone that does. Read paragraphs (c)(1) and (3) of Section 232.6 of the regulation: "Statement of the MAPR - (1) In general. ". . . Paragraph (a)(1) of this section shall not be construed as requiring a creditor to describe the MAPR as a numerical value . . ." (3) Model Statement. A statement substantially similar to the following statement may be used for the purpose of paragraph (a)(1) of this section . . ."

Also, the end of paragraph (a)(1) states that a payment schedule for closed end credit or account opening disclosure for open-end credit disclosed as required by Regulation Z satisfies the requirement to disclose the payment obligation.

Those are the reasons you can't find the disclosures you are looking for.