Military Lending Act
The Military Lending Act (MLA) places a Military Annual Percent Rate (MAPR) cap of 36% on covered loans. MAPR must include credit insurance premiums, fees for a credit‐related ancillary product, application fees, and fees imposed for participation in any plan or arrangement for consumer credit.
Identification of Covered BorrowersRegions has entered into an agreement with the credit bureaus to determine whether a consumer is an MLA covered borrower during the loan application process.
Mandatory Loan DisclosuresMLA requires lenders to provide both written and oral loan MAPR disclosures to covered borrowers before or at the time the borrower becomes obligated on the transaction or establishes an account. Regions provides the written and oral disclosures in person on branch-closed loans. As permitted by MLA, Regions provides a toll-free number for oral disclosure delivery on loans closed online or outside of a branch.
LimitationsThe MLA prohibits lenders from requiring covered borrowers:
- To waive their right to legal recourse under any provision of state or federal law, including the SCRA;
- To submit to arbitration or impose other onerous legal notice provisions in the case of a dispute;
- To meet the demands of unreasonable notice as a condition for legal action;
- To provide a check or other method of access to a deposit, savings, or other financial account maintained by the covered borrower;
- To establish an allotment to repay the obligation; and
- To pay a penalty fee for prepaying all or part of credit obligation