Description
Get an overview of the Military Lending Act and make sure you are compliant.In July 2020, the Department of Defense issued a Final Rule updating regulations implementing the Military Lending Act (MLA). These changes drastically expanded the scope of MLA coverage, now applying its restrictions to most types of ‘credit’ transactions covered by the Truth in Lending Act. These new rules apply generally to lenders extending consumer credit to activeduty service members, their family members, or dependents. The new rules provide safe harbor methods for identifying borrowers covered by the MLA, bans the use of certain practices, and changes the language of required disclosures. The new rules also contain important provisions about administrative enforcement, penalties, and remedies.
Date: 2021-08-27 Start Time: End Time:
Learning Objectives
Changes in Scope of Coverage
Determining If a Borrower Is a Covered Person Subject to the MLA; Obligation to Re-Verify
Understanding the Military Annual Percentage Rate (MAPR)
The 36% MAPR Cap
• Calculating MAPR for Closed-End Credit
• Calculating MAPR for Open-End Credit
The MAPR Disclosure Language
MAPR Disclosures and the Method of Delivery
Restrictions on the Content of Loan Agreements
• Legal Recourse, Class Action, and Jury Trial Waivers
• SCRA Protections
• Arbitration Provisions
• Mandatory Use of Allotments
• Prepayment Penalties
• Higher-Interest Loan Restrictions
New Administrative Rights and Enforcement
CFPB Interest in MLA Violations
CLE (Please check the Detailed Credit Information page for states that have already been approved) ,Additional credit may be available upon request. Contact Lorman at 866-352-9540 for further information.
Dowse B. (Brad) Rustin, IV-Nelson Mullins Riley & Scarborough LLP
