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For CUs that don't have access to MAPR calculators before the effective date or for a period of time after the effective date, CUNA is providing two MAPR loan calculators –one for closed-end loans and one for open-end loans that are subject to the Military Lending Act regulations. The calculators permit a credit union to make a manual determination of the MAPR and indicate when a combination of interest, fees and charges exceed 36%.
The calculators are located on CUNA's website:
- Under the Resources tab for the Military Lending Act topic in CUNA's eGuide
- In the Resources listing from the Compliance dropdown box on CUNA's Home page
- In CUNA's Compliance Community under, in the Compliance Resources dropdown box
Details Concerning the MAPR
The DoD's Military Lending Act rule prohibits a credit union from imposing a MAPR greater than 36 percent in connection with a loan made to a covered borrower. For closed-end loans the MAPR is calculated only one time--- at or before loan consummation. For open-end loans the MAPR is calculated during each billing cycle. If the MAPR exceeds 36%, a credit union would be expected to waive a sufficient amount of interest, fees, premiums, or charges to reduce the MAPR to 36% or below.
The numerical value of the MAPR is not required to be disclosed to the covered borrower. The MAPR is the cost of credit expressed as an annual percentage rate. The MAPR includes interest, other finance charges, premiums or fees for credit insurance, charges for single premium credit insurance, fees for a debt collection contract, or any fee for a debt suspension agreement, any fee for a credit-related ancillary product sold in connection with the loan, any fee imposed for participation in any plan, and any application fee charged to a covered borrower who applies for a consumer loan.
The MLA rule excludes an application fee charged by a Federal Credit Union, or an insured depositary institution, when making a short-term, small amount closed-end loan that is subject to and made in accordance with a Federal law. However, the application fee may only be excluded once in any rolling 12-month period. Therefore, an application fee charged to a covered borrower who applies for a second short-term small amount loan within 12-months of the first loan, may not be excluded from the MAPR calculation.
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