Lending to ServicemembeRs KNOWLEDGE. CLARITY. RELIABILITY. www.compliancealliance.com (888) 353-3933

Agenda Servicemembers Civil Relief Act Military Lending Act Comparison

SCRA Coverage Active-Duty Federal Military Dependents Obligors

SCRA Coverage Obligation BEFORE Active Duty After

SCRA Protections Adverse Action Interest Rate Cap Foreclosure Protection Installment Contracts Leases Enforcement of Storage Liens Eviction Life Insurance Dependents

Interest Rate Cap 6% Servicemember + Spouse Requested in Writing Only covered loans

Interest Rate Cap Interest Service Charges Renewal Charges Fees (including late fees) Any other charges (except insurance)

Foreclosure/Court Actions Non-Judicial Foreclosures Invalid Stay of Proceedings Active Duty + 1 year Representation HUD Notice

SCRA Penalties Fines Prison up to 1 year

2018 Amendments 2003 S.2155 McCain Amendment

Scenarios 1-3 PGS. 6-7

Arbitration Prohibition Military Lending Act MAPR limit Disclosure Arbitration Prohibition

Covered Borrower Active Duty Dependent

Dependent Parent or Parent-in-law Child or Ward: Spouse Ward depends on support resides in household Child or Ward: Under the age or 21; Under the age of 23 and a full-time college student; OR incapable of supporting themselves mental or physical incapacity Ward The Ward must also be unmarried

Identification Optional Safe Harbor 60 days Prior to Loan close Credit Report DoD Database Prior to Loan close 60 days

Covered Transactions Consumer Credit Regulation Z Open-End Loans Payday Loans Credit Cards Vehicle-Secured Loans Land-Only Loans

Residential Mortgages Exceptions Purchase Money Vehicle Purchase Residential Mortgages HELOCs/HE Reverse Mortgages Initial Construction Refis Business Loans

MAPR 36% Interest Fees Charges

Disclosures Written Oral Prior to Origination Regulation Z

Credit Insurance Premiums Credit Cards Bona-Fide Fees Periodic Interest Credit Insurance Premiums Debt Cancel/ Suspend Ancillary fees Like-Kind Fees

Prohibited Activities Rights Waiver Arbitration Unreasonable Notice Checks Allotment Prepayment

Regulatory Enforcement Liability Civil Penalties Fines Criminal Penalties Regulatory Enforcement

Scenarios 4-5 Pg. 12