CUNA
  • Advocacy
    • Priorities we’re fighting for
    • Actions you can take
  • News
  • Learn
  • Compliance
  • Shop
  • Topics
    • Community Service
    • Compliance
    • Credit Union Hero
    • Credit Union Rock Star
    • Credit Union System
    • Directors
    • Human Resources
    • Leadership
    • Lending
    • Marketing
    • Operations
    • Policy & Issues
    • Sales & Service
    • Technology
  • Credit Union Magazine
    • Buyers' Guide
    • COVID-19
    • Digital Edition
    • Credit Union Hero
    • Credit Union Rock Star
    • Subscribe
    • Advertise
    • Contact
  • COVID-19
  • Advertise
  • Awards
    • Nominate Credit Union Hero
    • Nominate Credit Union Rock Star
  • Podcasts
  • Videos
  • Contact
Learn More about Member Value

News

Member Benefits
Learn more
Learn more about the benefits of membership.
Home » Compliance: MLA back-to-basics, updated spreadsheet
Policy & Issues

Compliance: MLA back-to-basics, updated spreadsheet

July 29, 2019

CUNA has updated its Military Lending Act (MLA) credit card fee spreadsheet for the first quarter of 2019. The updated resource can be found in the CUNA Compliance Community’s “Compliance Resources” tab, and under the “Resources” tab in CUNA’s MLA e-Guide.

CUNA’s CompBlog also features a “back to basics” entry for the MLA, examining what loans are covered  and what loans are exempt from the rule, as well as information on who is a covered borrower.

Under a Safe Harbor in the MLA rule, a credit union may exclude a bona fide credit card fee from the MAPR if the fee is considered “reasonable,” meaning it must be less than or equal to the average fee for the same or similar product charged by five separate card issuers, that each have at least $3 billion in outstanding credit card balances at any time during the three-year period preceding the time the average is determined.

Currently, there are approximately 20 large card issuers that meet this requirement, and together they have about 260 card agreements in the CFPB’s Card Agreement Database, of which most are Private Label cards. Only about 85 of the agreements would appear to be useful for MLA purposes.

The exclusion generally applies to finance charges under Reg. Z such as cash advance fees, foreign transaction fees, balance transfer fees, transaction fees for purchases and minimum interest charges. Other charges, which are not finance charges under Reg. Z, such as a late fee or an over-limit fee are not included in the calculation of the MAPR anyway, so the exclusion would not apply to such fees.

The exclusion does not apply to fees or premiums for credit insurance, fees for a debt cancellation contract, fees for a debt suspension agreement, or to fees for a credit related ancillary product. Those fees must be included in the calculation of the MAPR.

In addition to the CompBlog, CUNA’s Compliance Community contains discussion boards and a number of other resources for credit union compliance professionals around the country.

KEYWORDS compliance MLA
Credit Union Magazine - Spring 2021

Spring 2021

Credit Union Magazine’s Spring 2021 edition features CUNA's 2021 advocacy agenda, strategic planning guidance, and labor market insights.
Digital Edition •  Subscribe

Trending

  • CFPB proposes foreclosure moratorium until 2022

  • Cheryl Deborde named Credit Union Hero of the Year

  • PCA flexibility coming soon from NCUA

Tweets by CUNA_News

Polls

How have vaccination efforts affected your remote work policy?

View Results
More

Champion of America’s Credit Unions

Credit Union National Association is the only national association that advocates on behalf of all of America’s credit unions. We work tirelessly to protect your best interests in Washington and all 50 states. We fuel your professional growth at every level and champion the credit union story at every turn.

More CUNA

  • About
  • Careers
  • Contact Us
  • Recommended Websites
  • Privacy Policy

Resources for

  • CUNA Board Members
  • Credit Union Advocates
  • Leagues
  • Press
  • Vendors