MLA Disclosures

Posted By: Comp@2005

MLA Disclosures - 05/03/17 12:42 PM

Final MLA rules require certain disclosures for covered borrowers, including the MAPR Statement and TILA disclosures. It is my understanding you don't have to actually provide consumer with the actual MAPR (numerical value) as Regulator thought that would be to confusing.

Please confirm.
Posted By: NSF, CRCM

Re: MLA Disclosures - 05/03/17 01:03 PM

You are correct. The act does not require use to provide the numerical value just the model statement provided.

(3) Model statement. A statement substantially similar to the following statement may be used for the purpose of paragraph (a)(1) of this section: "Federal law provides important protections to members of the Armed Forces and their dependents relating to extensions of consumer credit. In general, the cost of consumer credit to a member of the Armed Forces and his or her dependent may not exceed an annual percentage rate of 36 percent. This rate must include, as applicable to the credit transaction or account: The costs associated with credit insurance premiums; fees for ancillary products sold in connection with the credit transaction; any application fee charged (other than certain application fees for specified credit transactions or accounts); and any participation fee charged (other than certain participation fees for a credit card account)."
Posted By: Comp@2005

Re: MLA Disclosures - 05/03/17 01:19 PM

Thanks. I was pretty clear on this until I saw a recent compliance topic posted on BOL.

"Disclose the Military APR?"
Posted By: Andy Z

Re: MLA Disclosures - 05/05/17 09:03 PM

That doesn't mean you shouldn't know it or be able to audit it. You must be able to test your systems and LOS to know that the MAPR hasn't exceeded the allowed rate.