Course Details

The New Military Lending Act (MLA) Regulations: New Changes

Webinar: ID# 1023761
Recorded CD
About This Course:
The Department of Defense (DOD) amended the implementing regulations of the Military Lending Act (MLA) in 2015, expanding the scope of covered borrowers, covered products, and creating new limitations for lenders.

Most changes went into effect on October 3, 2016 and the deadline for compliance for new credit card accounts is October 3, 2017. The Rule subjects lenders to both civil liability and administrative enforcement for MLA violations in addition to the reputational risk of noncompliance.

This webinar helps lenders understand the new MLA requirements with a depth that will allow them to assess their institutional strategy and identify areas of risk. It will provide the information necessary to identify potential opportunities for operational streamlining and consolidation with existing SCRA requirements.

You will learn the permissible uses of the MLA database to avoid potential pitfalls. The content explains, in detail, how to calculate MAPR and the new safe harbor provisions. Additionally, you will be provided with the necessary tools to compare your policies and procedures with the key elements that regulators are looking for during examinations.

This program is critical for compliance professionals, in-house counsel, and mid-to-upper management at financial institutions offering consumer credit to ensure that their MLA strategy is both legally compliant and operationally efficient.


Overview of the Military Lending Act (MLA)
  • Brief Bird's-Eye View of the the MLA and the 2016–2017 Changes
  • Difference Between the MLA and SCRA
  • Definition of "Creditor" Under the Act
  • Implementation Rollout and Regulatory Examinations
Requirements of the MLA
  • MLA Requirements Already in Place
  • Scope and Impact of the 2016–2017 Changes to the MLA
  • How the Changes Have Broadened the Definition of "Consumer Credit"
  • How the MAPR Limits and Disclosures Have Changed
  • Restrictions on Loan Rollovers, Renewals, and Refinancing
How to Comply With Specific Provisions of the MLA
  • How to Identify Covered Borrowers
  • Operational Compliance Integration With the SCRA Requirements
  • Permissible Use of MLA Databases
  • How to Identify Covered Transactions and Exceptions
  • How to Calculate MAPR and How Is It Different From APR?
  • Savings Clauses in Standard Written Credit Agreements
What the Regulators Are Looking for When They Examine a Lender
  • A Compliance Management System With Policies and Procedures That Implement Controls Related to the MLA Requirements
  • A Lender's Policies and Procedures for Identifying Covered Borrowers
  • A Lender's Policies and Procedures for Calculating MAPR
  • The Sufficiency of a Lender's Mandatory Loan Disclosures
  • That the Lender Is Abiding by the Prohibitions on Rolling Over, Renewing, Repaying, or Refinancing
  • That the Lender Is Not Requiring a Covered Borrower to Waive Certain Rights or Provide Access to Certain Accounts
A Look Toward the Future
  • Review of Major Points
  • What We May Be Able to Expect With Regard to Enforcement
  • Changes on the Horizon
About The Presenter

Ashley M. Elmore Drew, Esq.
  • Attorney in the Tampa, Florida office of Burr & Forman LLP
  • Provides legal and regulatory compliance advisement and auditing services to financial services clients on a wide range of topics, including but not limited to the following: RESPA, SCRA, Third Party Relationship Risk Management, Bank use of Foreign-Based Service Providers, ECOA, FDCPA, FCRA, FACTA, UDAAP, and Regulation P. She also represents clients in a wide range of litigation to include claims asserted under TILA, RESPA, FDCPA, and TCPA
  • Recently featured in the Tampa Bay Business Journal, discussing the impact of the election on Dodd-Frank and the effect on community banks
  • Has written the following articles, “Opposition Mounts After Florida Court Eviscerates Lis Pendens”, published by Thompson Reuters in the Consumer Financial Services Law Report, Vol. 20, Issue 11, November 6, 2016, "CFPB Issues Examination Procedures for the Military Lending Act Rule", published by Burr Consumer Finance Litigation Blog on October 3, 2016; "New Risk from New Rules on Banker Pay", published by BAI, Banking Strategies on July 6, 2016; "The Best Defense is a Good Strategy: Planning for the Arbitration Rule", published by Burr Consumer Finance Litigation Blog on June 27, 2016; "Not Just the C-Suite: Regulators Issue Broad New Proposed Rule on Banker Compensation", published by Burr Consumer Finance Litigation Blog on April 25, 2016; "CFPB Receives Strategy Lesson—Court Holds it Overreached by Investigating For-Profit School Accreditation", published by Burr Consumer Finance Litigation Blog on April 27, 2016; "Do We Want the CFPB to Regulate the Practice of Law?", published by Burr Consumer Finance Litigation Blog on April 29, 2016; "NCUA Proposes Rule Easing Credit Union Commercial Property Occupancy Rule", published by Burr Consumer Finance Litigation Blog on June 29, 2016 and "Ctrl Alt Delete: CFPB says Mortgage Servicers Need Technological Reboot", published by Burr Consumer Finance Litigation Blog on June 29, 2016
The New Military Lending Act (MLA) Regulations: New Changes
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