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The New Military Lending Act (MLA) Regulations: New Changes

Get an overview of the Military Lending Act and make sure your strategy is both legally complaint and operationally efficient.

The Department of Defense (DOD) amended the implementing regulations of the Military Lending Act (MLA) in 2015, expanding the scope of covered borrowers, covered products, and creating new limitations for lenders. Most changes went into effect on October 3, 2016 and the deadline for compliance for new credit card accounts is October 3, 2017. The Rule subjects lenders to both civil liability and administrative enforcement for MLA violations in addition to the reputational risk of noncompliance. This topic helps lenders understand the new MLA requirements with a depth that will allow them to assess their institutional strategy and identify areas of risk. It will provide the information necessary to identify potential opportunities for operational streamlining and consolidation with existing SCRA requirements. You will learn the permissible uses of the MLA database to avoid potential pitfalls. The content explains, in detail, how to calculate MAPR and the new safe harbor provisions. Additionally, you will be provided with the necessary tools to compare your policies and procedures with the key elements that regulators are looking for during examinations. This workshop is critical for compliance professionals, in-house counsel, and mid-to-upper management at financial institutions offering consumer credit to ensure that their MLA strategy is both legally compliant and operationally efficient.

Runtime: 90 minutes
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Why Lorman?

Over 31 years and 1.4 million customers worth of experience providing continuing education. Our passion is providing you world-class training to help you succeed in business and as a professional.

Agenda

Overview of the Military Lending Act (MLA)

  • Brief Bird's-Eye View of the the MLA and the 2016-2017 Changes
  • Difference Between the MLA and SCRA
  • Definition of "Creditor" Under the Act
  • Implementation Rollout and Regulatory Examinations

Requirements of the MLA

  • MLA Requirements Already in Place
  • Scope and Impact of the 2016-2017 Changes to the MLA

- How the Changes Have Broadened the Definition of "Consumer Credit"

- How the MAPR Limits and Disclosures Have Changed

- Restrictions on Loan Rollovers, Renewals, and Refinancing

How to Comply With Specific Provisions of the MLA

  • How to Identify Covered Borrowers

- Operational Compliance Integration With the SCRA Requirements

- Permissible Use of MLA Databases

  • How to Identify Covered Transactions and Exceptions
  • How to Calculate MAPR and How Is It Different From APR?
  • Savings Clauses in Standard Written Credit Agreements

What the Regulators Are Looking for When They Examine a Lender

  • A Compliance Management System With Policies and Procedures That Implement Controls Related to the MLA Requirements
  • A Lender's Policies and Procedures for Identifying Covered Borrowers
  • A Lender's Policies and Procedures for Calculating MAPR
  • The Sufficiency of a Lender's Mandatory Loan Disclosures
  • That the Lender Is Abiding by the Prohibitions on Rolling Over, Renewing, Repaying, or Refinancing
  • That the Lender Is Not Requiring a Covered Borrower to Waive Certain Rights or Provide Access to Certain Accounts

A Look Toward the Future

  • Review of Major Points
  • What We May Be Able to Expect With Regard to Enforcement
  • Changes on the Horizon
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Why Lorman?

Over 31 years and 1.4 million customers worth of experience providing continuing education. Our passion is providing you world-class training to help you succeed in business and as a professional.

Credits

OnDemand Webinar

This program does NOT qualify, nor meet the National Standard for NASBA accreditation.

Audio & Reference Manual

This program does NOT qualify, nor meet the National Standard for NASBA accreditation.

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More Program Information

Why Lorman?

Over 31 years and 1.4 million customers worth of experience providing continuing education. Our passion is providing you world-class training to help you succeed in business and as a professional.

Faculty

Ashley M. Elmore Drew, Esq.

Ashley M. Elmore Drew, Esq.

Greenspoon Marder LLP

  • Senior Counsel in the Tampa office of Greenspoon Marder LLP
  • Provides legal and regulatory compliance guidance to business, real estate, and financial services clients on a wide range of Federal and State topics, including but not limited to the following: RESPA, SCRA, TILA, MLA, PACE Financing, Vendor Management, ECOA, FDCPA, FCRA, FACTA, UDAAP, FATCA, FACTA and myriad regulations. She also represents clients in regulatory and consumer defense litigation
  • Was featured in the Tampa Bay Business Journal, discussing the impact of the election on Dodd-Frank and the effect on community banks
  • Has written the following articles, “Opposition Mounts After Florida Court Eviscerates Lis Pendens”, published by Thompson Reuters in the Consumer Financial Services Law Report, Vol. 20, Issue 11, November 6, 2016, "CFPB Issues Examination Procedures for the Military Lending Act Rule", published by Burr Consumer Finance Litigation Blog on October 3, 2016; "New Risk from New Rules on Banker Pay", published by BAI, Banking Strategies on July 6, 2016; "The Best Defense is a Good Strategy: Planning for the Arbitration Rule", published by Burr Consumer Finance Litigation Blog on June 27, 2016; "Not Just the C-Suite: Regulators Issue Broad New Proposed Rule on Banker Compensation", published by Burr Consumer Finance Litigation Blog on April 25, 2016; "CFPB Receives Strategy Lesson—Court Holds it Overreached by Investigating For-Profit School Accreditation", published by Burr Consumer Finance Litigation Blog on April 27, 2016; "Do We Want the CFPB to Regulate the Practice of Law?", published by Burr Consumer Finance Litigation Blog on April 29, 2016; "NCUA Proposes Rule Easing Credit Union Commercial Property Occupancy Rule", published by Burr Consumer Finance Litigation Blog on June 29, 2016 and "Ctrl Alt Delete: CFPB says Mortgage Servicers Need Technological Reboot", published by Burr Consumer Finance Litigation Blog on June 29, 2016
  • Can be contacted at 813-769-7038 or [email protected]
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Product ID: 399624
Published 2017
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