Financial institutions have been implementing new regulations through board-approved procedures for decades. As existing regulations are revised and new regulations are published existing procedures need to be updated. Procedure Updates are designed to simplify the task of updating existing procedures, regardless of where the existing requirement is lodged. Procedure Updates include operating procedures, controls and audit procedures. Each set of procedures are completely customizable. You may add the name of the financial instruction, the name of the person responsible for taking action, or make any other needed changes.
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 (MLA) Procedures Update contains an overview of the MLA requirements, a regulatory citation, the effective date, and includes operating procedures, control procedures, and audit procedures to ensure compliance with the Military Lending Act requirements.