Effective on October 3, 2016 the Military Lending Act (MLA) final rule:
1) Extends MLA protections, including the 36 percent Military Annual Percentage Rate (MAPR) cap, to a wider range of credit products, including credit cards.
2) Modifies the MAPR to include fees for credit-related ancillary products sold in connection with the credit transaction, finance charges associated with consumer credit, and certain application and participation fees. Also, for credit cards, the MAPR excludes certain fees if bona fide and reasonable.
3) Provides a safe harbor for creditors ascertaining whether a consumer is covered by the final rule’s protections.
4) Modifies the existing prohibition on rolling over, renewing or refinancing consumer credit. Subjects creditors to civil liability and administrative enforcement for MLA violations.
The Military Lending Act Policy Update communicates the Board’s intent to comply with the requirements of the Military Lending Act.