Military Lending - 11th Hour Checklist

WHAT?

The DOD recently amended its Military Lending Act regulations primarily for the purpose of extending the protections of the MLA to a broader range of credit products. The revised regulations also revise several defined terms. add two safe harbor methods for determining if an individual is a covered borrower, provide details on the proper calculation of the Military Annual Percentage Rate (MAPR), and add clarification on the content of disclosures and the scope of special limitations. While many lenders have avoided offering covered loans in the 10 years the MLA has been around, the scope changes in the new rules will make avoidance nearly impossible.
Compliance is mandatory, for the most part, on October 3, 2016. Before consummating the first covered closed-end loan or establishing the first covered open-end line on October 3, 2016, all creditors should have in place a standard operating procedure to ensure compliance with the Military Lending Act.

WHY?
This information-packed program provides last minute preparation for the October 3, 2016 mandatory compliance date. This program also points out MLA problem areas and proposes practical solutions to those problems. Participants receive a detailed manual.

PROGRAM CONTENT
Upon completion of the program, participants should understand:

Upon completion of the program, participants should understand:

• How to determine whether a transaction is covered or exempt;
• How to determine and verify which applicants are "covered borrowers," including use of:
• The DoD database;
• Credit reports; and
• Other methods
• How to identify dependents of a covered member;
• Required disclosures, including:
• Content of the disclosure;
• Timing of the disclosure; and
• Written and oral delivery;
• How to calculate the MAPR and ensure compliance with the 36% limit on the MAPR:
• Complying with the 36% limit is a bigger challenge than it first appears;
• Alternative calculations if loan origination and/or core accounting software is not up to the task;
• APRWIN software;
• Calculator, pen and paper;
• Limitations on creditor acts or practices:
• Which of the limitations apply to financial institutions?
• Clarification of the prohibition on taking an account or a certificate of deposit as collateral;
• Implementation issues, including:
• The need for policies and procedures;
• The capabilities of loan origination and core accounting software;
• Recordkeeping requirements;
• The effective and mandatory compliance dates; and
• Penalties and remedies.

WHO?
The program is designed for loan officers, compliance officers, loan processors and clerks, auditors, and everyone else with responsibilities related to consumer lending. The whole consumer lending team needs to participate in this 11th Hour program