Military APR Requirements are right around the corner… Are you ready? We are…
As October 3rd approaches, the Carleton team wants to ensure that our partners are equipped to comply with the new Military Lending Act requirements.
The maximum 36% Military Annual Percentage Rate (MAPR) requirement has been in effective since January 2007 but only applied to payday, vehicle title, and refund anticipation loan products. Effective October 3, 2016, nearly all loan products provided by lenders extending credit to active military personnel must comply with the maximum 36% MAPR.
“Military Interest” included the finance charge as defined in TIL Reg. Z as well as the following fees and premiums items:
- Application fees (new requirement)
- Points, origination fees, participation fees – all fees in the TILA Reg. Z finance charge
- Any premium or fee for credit insurance.
- Any debt protection charges/fees (cancellation and suspension)
- Any credit-related ancillary product sold in conjunction with the transaction
The Carleton CarletonCalcs Origination Module has been updated to define which fees will be included or excluded for purposes of calculating the Military Interest and MAPR. This update to CarletonCalcs will enable our partner’s lenders to individually define which fees will be treated as Military Interest for each individual loan product.
If you have any questions regarding this release and how Carleton can help you stay compliant with the MAPR requirements, contact your Carleton sales or support representatives at (800)433-0090.
Posted on Sep 15, 2016