Mon. ICBA Summary of the Military Lending Act Updated Regulation. August Month Year. Contact:

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1 ICBA Summary of the Military Lending Act Updated Regulation August 2015 Month Year Mon Contact: Joe Gormley Assistant Vice President & Regulatory Counsel

2 ICBA Summary of Military Lending Act Updated Regulation BACKGROUND On July 21, 2015, the Department of Defense ( DOD ) issued its final rule amending the Military Lending Act 2015 ( MLA ) 1 regulations. The final rule extends the types of closed-end and open-end consumer credit products covered under the MLA to include those aligned with the definition of credit under the Truth in Lending Act ( TILA ) and Regulation Z: credit offered or extended to a covered borrower primarily for personal, family, or household purposes, and that is (i) subject to a finance charge or (ii) payable by a written agreement in more than four installments. The final rule still carves out an exemption for residential mortgages and vehicle-secured purchase loans. Additionally, the final rule modifies the process for a creditor determining whether a consumer is a covered borrower, modifies the disclosures, and implements the MLA enforcement provisions. The effective date of the final rule is October 1, In general, compliance with the final rule is required by October 3, 2016, however, this date is extended to October 3, 2017, for credit card accounts. Consumer credit that is extended and consummated before October 3, 2016, will be covered under the current regulation. Congress passed the Military Lending Act in 2006 with the goal of protecting active-duty military personnel, active National Guard or Reserve Personnel, and their dependents engaged in consumer credit transactions. The MLA and its current regulation 2 apply to closed-end payday loans capped at $2,000 and a 91-day term, closed-end auto title loans with terms of 181 days or fewer and closed-end tax refund anticipation loans. Among its other provisions, the regulation limits the interest rate at 36 percent, requires certain disclosures regarding service members rights and prohibits lenders from requiring arbitration in the event of a dispute. The MLA is implemented by the DOD and is enforced by the Consumer Financial Protection Bureau ( CFPB ) and other federal regulators. In May of 2012, the DOD and CFPB released a Joint Statement of Principles on Consumer Financial Protection wherein both agencies pledged to identify ways to increase the effectiveness of the MLA and 32 CFR Part 232 through new legislation or rulemaking. Subsequently, the DOD proposed amendments to its MLA regulation to extend the coverage of the MLA to include additional consumer credit products in an effort to provide greater protections to service members and their families U.S.C CFR part 232. August 2015 ICBA Summary of the Military Lending Act Updated Regulation 1

3 FINAL RULE COVERAGE Military Annual Percentage Rate (MAPR) Calculation Under the MLA, covered credit transactions are capped at a 36% Annual Percentage Rate. This rate is referred to as the Military Annual Percentage Rate ( MAPR ). For closed-end credit, the MAPR is calculated the same way an Annual Percentage Rate ( APR ) is calculated under Regulation Z. Even if not provided for in Regulation Z, the MAPR amount must also include the following: 1. Credit Insurance Premium or Fee 2. Debt Cancellation or Debt Suspension Fee 3. Fees for Ancillary Products Sold in Connection with the Credit Transaction (e.g. Credit Default Insurance and Debt Suspension Plans) 4. Finance Charges 5. Application Fee The MAPR for open-end credit must be calculated in the same way as an effective annual percentage rate for a billing cycle as required by Regulation Z. 3 The MAPR must also include the fees described above. If there is no balance in a billing cycle, a creditor may not charge any fee except for a participation fee. The participation fee cannot exceed $100 per year regardless of the billing cycle in which the fee is imposed. This limitation does not apply to a bona fide participation fee which is excluded from the MAPR for credit card accounts. IDENTIFICATION OF COVERED BORROWER The final rule provides a safe harbor to a creditor who continues to rely on a borrower identification statement provided by the service member that discloses their military status to a creditor through October 3, After which time, the creditor may apply its own method of assessing whether or not a consumer is a covered borrower, including relying on the service member s statement. Under the MLA, a covered borrower is an individual serving on active duty in the military or that individual s spouse or child. However, according to the final rule, a creditor may conclusively determine the borrower s status and thereby obtain a safe harbor only by electing one of the following two methods for conducting a covered-borrower check: 1) using information obtained directly or indirectly from the MLA Database; or 2) relying on information contained in a consumer report obtained from a nationwide consumer reporting agency; and 3) complying with recordkeeping requirements. The creditor may also rely on commercial information-services providers that include covered-borrower checks obtained from the MLA Database as part of the products used to process loan applications. If the creditor chooses to rely on information obtained from a nationwide credit reporting agency to obtain safe harbor status, it may use the products and services of a reseller, as that term is defined in the Fair Credit Reporting Act, of such consumer reports. The creditor seeking safe harbor must also timely 3 12 CFR (c) and (d). August 2015 ICBA Summary of the Military Lending Act Updated Regulation 2

4 create and maintain a record of the information used to determine whether or not the consumer was a covered borrower. Timing of Determination of Covered Borrower Status The creditor may only rely on an initial determination of a covered borrower: 1. When a consumer initiates the transaction or 30 days prior; 2. When consumer applies to establish an account or 30 days prior; or 3. When the creditor develops or processes a firm offer of credit and the covered borrower responds within 60 days. If the covered borrower does not respond within 60 days, the creditor may no longer rely on the initial determination. DISCLOSURES In addition to eliminating the clearly and conspicuously requirement, the final rule simplifies the information a creditor must provide before or at the time the covered borrower becomes obligated for a transaction or when the account is originally established. In addition to providing disclosures required by Regulation Z, a creditor will be required to provide a statement of the MAPR that describes the charges the creditor may impose, but will no longer be required to provide the periodic rate of the MAPR and the total dollar amount of all charges included in the MAPR. The creditor must also provide a clear description of the payment obligation, which can be satisfied by using a payment schedule or account-opening disclosure as required by Regulation Z. In addition to the written disclosures required, the creditor must provide: 1) the statement of the MAPR; and 2) a description of the payment obligation orally. However, a creditor may now provide the oral disclosures either in person or by providing a toll-free number the borrower may use to obtain the disclosures. If the creditor elects to provide a toll-free number, it must include that number on the application form or with the statement of the MAPR. The new rule eliminates the requirement that a creditor provide a specific statement regarding the protections available to covered borrowers under federal law (Statement of Federal Protections). For refinancing or a renewal of the covered loan, new disclosures are required only when the transaction is considered a new transaction requiring Regulation Z disclosures. The final rule also modified 232.6(b) (2) to clarify that if two or more creditors are involved in a transaction, disclosures are only required by one of them. The creditors are permitted to agree which creditor will provide the information required by the MLA. August 2015 ICBA Summary of the Military Lending Act Updated Regulation 3

5 Model Statement The final rule provides a model statement describing the MAPR. A creditor may use the model statement or a substantially similar statement. 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%. 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). APPLICATION OR PARTICIPATION FEES INSURED DEPOSITORY INSTITUTIONS While there is no overall exemption for community banks or other insured depository institutions from the final rule, it does permit these institutions to exclude the application fee charged when making a short-term, small-amount loan from the MAPR computation. The final rule specifies that this exception will apply only to a closed-end loan that is subject to Federal law other than the MLA that limits the interest rate or cost on an extension of credit where the limitation is comparable to an APR of 36 percent. It further defines this type of loan as one that cannot exceed 9 months and one that has a fixed limit on an application fee. If the creditor charges a second application fee to a borrower who applies for a second short-term, small-amount loan within a 12-month period, the second fee is not eligible for the exclusion. CONDITIONAL EXCLUSION FOR CREDIT CARD ACCOUNTS The final rule carves out an exclusion from the calculation of the MAPR for credit card accounts for any bona fide fee, other than the periodic rate, including application fees, participation fees, transactionbased fees and similar fees tied to the use of a credit card. This exclusion does not apply to credit insurance premiums, debt cancellation or debt suspension fees, or any ancillary product fees. The excluded charges must be bona fide and reasonable for that type of fee. The rule requires a like-kind standard and provides that a creditor must compare fees typically imposed by other creditors for the same or substantially similar product or service to determine reasonableness. A creditor can obtain a safe harbor for this exclusion if it compares the bona fide fee to an average amount charged by 5 or more creditors. Each of the 5 or more creditors must have U.S. credit cards that in total have an outstanding balance of $3 billion at any time during the 3-year period preceding the time the average is computed. The creditor s charge for that fee is reasonable if it is equal to or less than the average amount. August 2015 ICBA Summary of the Military Lending Act Updated Regulation 4

6 Reasonableness of a Participation Fee A participation fee for a credit card account will be considered reasonable if the charge reasonably corresponds to the credit limit of the account or the services offered under the account. A creditor may charge more for a participation fee and it will still be considered reasonable if the fee is relative to either an increased credit limit or additional services or benefits offered under the account. LIMITATIONS Rollover Restrictions As previously noted, DOD s current regulation defines creditor to a narrow category of persons engaged in the business of extending a limited number of consumer credit products. Overall, the final rule expands the definition of creditor to reflect a wider range of consumer credit products and thereby expanding and redefining creditors that are included. However, for the purposes of the rollover restrictions in 232.8(a), the DOD has included a new definition of creditor restricting its application to include only persons engaged in deferred presentment transactions and payday loan transactions (a) of the final rule makes it unlawful for a creditor who previously extended a deferred presentment transaction or payday loan to a covered borrower to rollover, renew, repay, refinance, or consolidate consumer credit to the same covered borrower. The definition does carve out an exception for a person that is chartered or licensed under Federal or State law as a bank, savings association, or credit union. 4 Vehicle Title Restriction The final rule adds a provision in that excludes any creditor that is chartered or licensed under Federal or State law including banks, savings associations or credit unions from the restriction of using the title of a vehicle as a security obligation for the consumer credit. 5 PENALTIES AND REMEDIES The final rule added new language 6 to reflect the civil liability provisions of the MLA enacted in the 2013 Act. 7 A creditor is required to show by a preponderance of the evidence that the violation was not intentional and was the result of a bona fide error. The civil liability provisions include: 1. Actual damage sustained, not less than $500 for each violation; 2. Punitive damages; 3. Equitable or declaratory relief; 4. Any other relief provided by law; and 5. Costs of the action, including reasonable attorney fees CFR 232.8(a) CFR 232.8(f) CFR 232.9(e) U.S.C. 662(b) of the 2013 Act. August 2015 ICBA Summary of the Military Lending Act Updated Regulation 5

7 COMPLIANCE SUGGESTIONS Community banks may want to utilize a toll-free number for the service member or dependent to call to obtain the required oral disclosure which may reduce the risk of human error as well as the need for additional training. The toll-free number must be displayed on the application form or with the statement of the MAPR. Community banks should use the model language describing the MAPR. Community banks should perform due diligence on their affected service providers and processors to ensure that any required system changes are made by October 3, 2016, to ensure MLA compliance. If a bank currently uses a commercial service provider to process loan applications, the bank should confirm whether or not the service provider is checking the MLA Database as part of their lending services to determine a covered borrower. If yes, the bank should confirm that the service provider will continue that service and in compliance with the final rule. The bank should either: 1) rely on the service provider to perform the MLA covered borrower search; or 2) obtain the consumer credit report from a nationwide Consumer Reporting Agency. The consumer credit report can also be obtained through a reseller. Using one of these two methods may reduce human error and, reduce the need for extensive training. August 2015 ICBA Summary of the Military Lending Act Updated Regulation 6

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