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Lending to ServicemembeRs
KNOWLEDGE. CLARITY. RELIABILITY. (888)
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Agenda Servicemembers Civil Relief Act Military Lending Act Comparison
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SCRA Coverage Active-Duty Federal Military Dependents Obligors
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SCRA Coverage Obligation BEFORE Active Duty After
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SCRA Protections Adverse Action Interest Rate Cap
Foreclosure Protection Installment Contracts Leases Enforcement of Storage Liens Eviction Life Insurance Dependents
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Interest Rate Cap 6% Servicemember + Spouse Requested in Writing
Only covered loans
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Interest Rate Cap Interest Service Charges Renewal Charges
Fees (including late fees) Any other charges (except insurance)
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Foreclosure/Court Actions
Non-Judicial Foreclosures Invalid Stay of Proceedings Active Duty + 1 year Representation HUD Notice
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SCRA Penalties Fines Prison up to 1 year
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2018 Amendments 2003 S.2155 McCain Amendment
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Scenarios 1-3 PGS. 6-7
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Arbitration Prohibition
Military Lending Act MAPR limit Disclosure Arbitration Prohibition
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Covered Borrower Active Duty Dependent
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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
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Identification Optional Safe Harbor 60 days Prior to Loan close
Credit Report DoD Database Prior to Loan close 60 days
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Covered Transactions Consumer Credit Regulation Z Open-End Loans
Payday Loans Credit Cards Vehicle-Secured Loans Land-Only Loans
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Residential Mortgages
Exceptions Purchase Money Vehicle Purchase Residential Mortgages HELOCs/HE Reverse Mortgages Initial Construction Refis Business Loans
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MAPR 36% Interest Fees Charges
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Disclosures Written Oral Prior to Origination Regulation Z
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Credit Insurance Premiums
Credit Cards Bona-Fide Fees Periodic Interest Credit Insurance Premiums Debt Cancel/ Suspend Ancillary fees Like-Kind Fees
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Prohibited Activities
Rights Waiver Arbitration Unreasonable Notice Checks Allotment Prepayment
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Regulatory Enforcement
Liability Civil Penalties Fines Criminal Penalties Regulatory Enforcement
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Scenarios 4-5 Pg. 12
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