- Military Lending Act Compliance
- March 28, 2017 | Author: Ashley Michelle Elmore Drew
- Law Firm: Burr & Forman LLP - Tampa Office
- On October 3, 2017, the Department of Defense’s revised Military Lending Act (“MLA”) regulations will apply to consumer credit card accounts. These regulations require significant changes and will alter the landscape of how cards are marketed and offered.
Credit card issuers may no longer rely on the customer’s representations as to covered status. Creditors must develop MAPR calculators, which take into account the complex bona fide fee rules and monitor limits each billing cycle. They must monitor new account holders to determine whether they have become covered servicemembers or dependents of covered servicemembers. They must work with their retail partners if they offer cards at point of sale to ensure the appropriate oral and written disclosures are made and documented. The consequences of non-compliance are severe: the debt is considered void at inception; there are civil and criminal penalties; and there is significant reputational risk
Download the full article, “Burr Alert: Military Lending Act Compliance.”