Take a deep breath, it’s just another rule

first_imgMy inbox has been quite full recently, as credit unions are gearing up for the implementation of the Military Lending Act revisions which are effective at the beginning of October.  That is to be expected, as the revised rule impacts credit unions much more significantly than it had in the past.However, the degree of apprehension I have been sensing from credit unions is quite high, and that is unfortunate.  I believe that much of this anxiety is caused by the lack of clarification and guidance on the part of the Department of Defense.  Although we’ve endured significant mortgage lending rules in recent years, the CFPB was very good about providing resources and communication regarding their expectations.  While at times we may have hoped for even more, their charts and “plain language” small entity compliance guides were quite helpful.  Unfortunately, with the MLA revisions, we’ve been left to make some interpretations and judgment calls based upon the language which exists.Although information is a little harder to come by, there are a few resources which might be helpful.   First, and foremost is the final rule itself.  It may appear a bit daunting at 54 pages but, reading the final rule can provide valuable insight.  Particularly in this case, where guidance is limited.  The rule can provide an awareness of the DoD’s thought process and expectations, which may assist credit unions in determining the spirit of the rule.   For example, the following language provides background on the DoD’s decision to include credit insurance premiums in the MAPR calculation: continue reading » ShareShareSharePrintMailGooglePinterestDiggRedditStumbleuponDeliciousBufferTumblrlast_img

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