SlideShare uma empresa Scribd logo
1 de 11
Baixar para ler offline
Protecting and Serving
Military Credit Consumers
1.46 million active personnel in the U.S. military.
http://us-military-branches.insidegov.com/app-question/443/How-many-people-are-there-in-the-US-military 
http://www.globalfirepower.com/country-military-strength-detail.asp?country_id=united-states-of-america
http://www.nctsn.org/resources/public-awareness/month-military-child
http://download.militaryonesource.mil/12038/MOS/Reports/2014-Demographics-Report.pdf
http://download.militaryonesource.mil/12038/MOS/Reports/2014-Demographics-Report.pdf
Military by the Numbers
86.8% of active duty enlisted members are stationed in the
United States and U.S. territories.
49.6% of active duty enlisted personnel are 25 years of age
or younger
2 million military children in the U.S., ranging in ages from
newborn to 18 years old; 1.3 million military children are school-aged
1.1 million active reserve personnel in the U.S. military.
With members of the U.S. military making the ultimate
sacrifice – service to country – the government has
created several protections to assist with “consumer
credit” transactions and their financial lives.
Military Lending Act
Military Lending Act (MLA)
– New in 2016
Primary Goal: Protect active-duty soldiers from high-rate loans, such as payday loans,
car title loans and tax-refund anticipation loans.
• Originally passed by Congress in 2006 and implemented by the Department of
Defense (DOD) in 2007
What it covers:
• 36% interest rate cap on covered loans to active duty service members
• Required disclosures to alert service members to their rights
• Prohibits creditors from requiring a service member to submit to arbitration in the
event of a dispute
New rules were introduced in July 2015 and became effective on October 1, 2015.
Compliance is required by October 3, 2016, but rules for credit cards is delayed
until October 3, 2017.
• Now includes addition of fees paid “for a credit-related ancillary product sold
in connection with the credit transaction.” Although the MAPR limit is 36%,
ancillary product fees can add up and exceed the MAPR limit.
• Includes a “safe harbor” from liability for lenders who verify the MLA status of a
consumer.
• Lenders need to identify who is in active military duty at origination, obtaining
information directly or indirectly from the Department of Defense’s
DMDC database.
New MLA Regulations
“When I drive down a strip
outside a military installation
and count 20 fast-cash lenders
in less than 4 miles, that’s not a
convenience, that’s a problem.”
– Holly Petraeus, CFPB Assistant Director
Servicemembers
Civil Relief Act
Primary Goal: Offer an umbrella of protections to military personnel whose service
duties conflict with the financial obligations they have as civilians.
• Originally called the Soldiers and Sailors Civil Relief Act when first passed in 1918.
• Got its current name when rewritten and expanded again in 2003
What it covers:
• An interest rate cap of 6% on loans military service members incurred prior to
becoming active. Applies to any charges – including credit card debt, service charges
and renewal charges or fees – except bona fide insurance. Federally guaranteed
student loans were added in 2008.
• Accounts of the service member, or joint accounts of the service member and the
service member’s spouse, are additionally eligible.
To receive the interest rate reduction, a service member must request it in
writing and include a copy of his or her military orders.
Servicemembers Civil Relief Act (SCRA)
Best Practices to Serve
Military Consumers in
Financial Services
As a lender, you must adhere to SCRA and MLA regulations, so ensure you have
systems and governance in place to manage compliance.
Consider adding pages to your website, providing information on SCRA and MLA,
so military customers understand their rights and how to best work with you.
If you offer additional military benefits, communicate these. Many lenders offer
military rebate programs – don’t be shy in advertising these discounts.
1
2
3
To learn more about how Experian can help you best service
you military consumers and adhere to regulations like MLA
and SCRA, visit experian.com/military
© 2016 Experian Information Solutions, Inc. • All rights reserved.
Experian and the Experian marks used herein are trademarks or registered trademarks
of Experian Information Solutions, Inc. Other product and company names mentioned herein are the property of their respective owners.
This information is for educational purposes only. It is not intended to be nor should it be relied upon as legal advice.
If you have questions about the information contained herein, you should consult your own legal and compliance departments.

Mais conteúdo relacionado

Mais procurados

Issues in fisheries sustainability
Issues in fisheries sustainabilityIssues in fisheries sustainability
Issues in fisheries sustainability
Michael Newbold
 

Mais procurados (14)

Aquaculture: global status and trends
Aquaculture: global status and trendsAquaculture: global status and trends
Aquaculture: global status and trends
 
Seminar
SeminarSeminar
Seminar
 
Different types of fertilizers & manures used in
Different types of fertilizers & manures used inDifferent types of fertilizers & manures used in
Different types of fertilizers & manures used in
 
UN Fish stock Agreement, Shared fish stocks, FAO compliance agreement& Confli...
UN Fish stock Agreement, Shared fish stocks, FAO compliance agreement& Confli...UN Fish stock Agreement, Shared fish stocks, FAO compliance agreement& Confli...
UN Fish stock Agreement, Shared fish stocks, FAO compliance agreement& Confli...
 
Traditional Fishing Craft of Gujarat.pptx
Traditional Fishing Craft of Gujarat.pptxTraditional Fishing Craft of Gujarat.pptx
Traditional Fishing Craft of Gujarat.pptx
 
Intergrated paddy cum-fish culture
Intergrated paddy cum-fish cultureIntergrated paddy cum-fish culture
Intergrated paddy cum-fish culture
 
monosex tilapia and gift tilapia
monosex tilapia and gift tilapiamonosex tilapia and gift tilapia
monosex tilapia and gift tilapia
 
Role of aquatic resources in food and nutrition
Role of aquatic resources in food and nutritionRole of aquatic resources in food and nutrition
Role of aquatic resources in food and nutrition
 
Fresh Water Fish Habitat Management
Fresh Water Fish Habitat ManagementFresh Water Fish Habitat Management
Fresh Water Fish Habitat Management
 
Better Management Practices for good aquaculture plannimng and management by ...
Better Management Practices for good aquaculture plannimng and management by ...Better Management Practices for good aquaculture plannimng and management by ...
Better Management Practices for good aquaculture plannimng and management by ...
 
Radio broadcasting
Radio broadcastingRadio broadcasting
Radio broadcasting
 
Biology of finfish 2nd semester (full sylabus)
Biology of finfish 2nd semester (full sylabus)Biology of finfish 2nd semester (full sylabus)
Biology of finfish 2nd semester (full sylabus)
 
Indigenous ornamental fishes
Indigenous ornamental fishesIndigenous ornamental fishes
Indigenous ornamental fishes
 
Issues in fisheries sustainability
Issues in fisheries sustainabilityIssues in fisheries sustainability
Issues in fisheries sustainability
 

Destaque

Destaque (12)

Servicemembers Civil Relief Act Simplified
Servicemembers Civil Relief Act SimplifiedServicemembers Civil Relief Act Simplified
Servicemembers Civil Relief Act Simplified
 
Summer Sizzle for Vehicle Sales: Trends, Insights and Tips to Capitalize
Summer Sizzle for Vehicle Sales: Trends, Insights and Tips to CapitalizeSummer Sizzle for Vehicle Sales: Trends, Insights and Tips to Capitalize
Summer Sizzle for Vehicle Sales: Trends, Insights and Tips to Capitalize
 
Post-Election 2016: What's on the horizon for the financial services industry?
Post-Election 2016: What's on the horizon for the financial services industry?Post-Election 2016: What's on the horizon for the financial services industry?
Post-Election 2016: What's on the horizon for the financial services industry?
 
Must-Know Details About the Military Lending Act
Must-Know Details About the Military Lending ActMust-Know Details About the Military Lending Act
Must-Know Details About the Military Lending Act
 
Are Millennials Mortgage-Ready?
Are Millennials Mortgage-Ready?Are Millennials Mortgage-Ready?
Are Millennials Mortgage-Ready?
 
5 Reasons to Report Credit Data
5 Reasons to Report Credit Data5 Reasons to Report Credit Data
5 Reasons to Report Credit Data
 
5 steps to boost your accuracy in data reporting
5 steps to boost your accuracy in data reporting5 steps to boost your accuracy in data reporting
5 steps to boost your accuracy in data reporting
 
How lenders can capitalize on the growth in personal loans
How lenders can capitalize on the growth in personal loansHow lenders can capitalize on the growth in personal loans
How lenders can capitalize on the growth in personal loans
 
The Art and Science of Implementing Faster Decisioning
The Art and Science of Implementing Faster DecisioningThe Art and Science of Implementing Faster Decisioning
The Art and Science of Implementing Faster Decisioning
 
How consumer credit scores fared in 2016
How consumer credit scores fared in 2016How consumer credit scores fared in 2016
How consumer credit scores fared in 2016
 
Top 5 financial trends and twists of 2017
Top 5 financial trends and twists of 2017Top 5 financial trends and twists of 2017
Top 5 financial trends and twists of 2017
 
Revolutionizing lending in today's digital world
Revolutionizing lending in today's digital worldRevolutionizing lending in today's digital world
Revolutionizing lending in today's digital world
 

Semelhante a Protecting and Serving Military Credit Consumers

Securing_Americas_Financial_Future
Securing_Americas_Financial_FutureSecuring_Americas_Financial_Future
Securing_Americas_Financial_Future
Joshua Powell
 
Dmc overview generic
Dmc overview generic Dmc overview generic
Dmc overview generic
Chris Norton
 
Roles.Agents.Navigators.Play.In.Exchanges.Eba.Article.4.1.11
Roles.Agents.Navigators.Play.In.Exchanges.Eba.Article.4.1.11Roles.Agents.Navigators.Play.In.Exchanges.Eba.Article.4.1.11
Roles.Agents.Navigators.Play.In.Exchanges.Eba.Article.4.1.11
Robert Hutt
 

Semelhante a Protecting and Serving Military Credit Consumers (20)

JJ MONTANARO and GREGG RIVAS - THE NEW MILITARY BLENDED RETIREMENT SYSTEM: ST...
JJ MONTANARO and GREGG RIVAS - THE NEW MILITARY BLENDED RETIREMENT SYSTEM: ST...JJ MONTANARO and GREGG RIVAS - THE NEW MILITARY BLENDED RETIREMENT SYSTEM: ST...
JJ MONTANARO and GREGG RIVAS - THE NEW MILITARY BLENDED RETIREMENT SYSTEM: ST...
 
MBA Compliance Essentials Successor-In-Interest State Report - California
MBA Compliance Essentials Successor-In-Interest State Report - CaliforniaMBA Compliance Essentials Successor-In-Interest State Report - California
MBA Compliance Essentials Successor-In-Interest State Report - California
 
AmeriCorps Planning Grants 101
AmeriCorps Planning Grants 101AmeriCorps Planning Grants 101
AmeriCorps Planning Grants 101
 
This Week In Military Community and Family Policy 05 Feb 2010 Pdf
This Week In Military Community and Family Policy 05 Feb 2010 PdfThis Week In Military Community and Family Policy 05 Feb 2010 Pdf
This Week In Military Community and Family Policy 05 Feb 2010 Pdf
 
Military.Com Presentation 082508
Military.Com Presentation 082508Military.Com Presentation 082508
Military.Com Presentation 082508
 
Securing_Americas_Financial_Future
Securing_Americas_Financial_FutureSecuring_Americas_Financial_Future
Securing_Americas_Financial_Future
 
Dmc overview generic
Dmc overview generic Dmc overview generic
Dmc overview generic
 
SVAG - Testimony for HR 3483 "The Veterans Education Equity Act of 2011"
SVAG - Testimony for HR 3483 "The Veterans Education Equity Act of 2011"SVAG - Testimony for HR 3483 "The Veterans Education Equity Act of 2011"
SVAG - Testimony for HR 3483 "The Veterans Education Equity Act of 2011"
 
Consumer and Credit Reporting Webinar Powerpoints
Consumer and Credit Reporting Webinar PowerpointsConsumer and Credit Reporting Webinar Powerpoints
Consumer and Credit Reporting Webinar Powerpoints
 
vsogrant_app_1314
vsogrant_app_1314vsogrant_app_1314
vsogrant_app_1314
 
Irrigation Association State Affairs Indiana Presentation(02 15-2011)
Irrigation Association State Affairs Indiana Presentation(02 15-2011)Irrigation Association State Affairs Indiana Presentation(02 15-2011)
Irrigation Association State Affairs Indiana Presentation(02 15-2011)
 
CFPB Hot Topics in 2016
CFPB Hot Topics in 2016 CFPB Hot Topics in 2016
CFPB Hot Topics in 2016
 
Proven Leaders Among Us: The Case for Hiring Returning Veterans
Proven Leaders Among Us: The Case for Hiring Returning VeteransProven Leaders Among Us: The Case for Hiring Returning Veterans
Proven Leaders Among Us: The Case for Hiring Returning Veterans
 
Student Loans & Service Members
Student Loans & Service MembersStudent Loans & Service Members
Student Loans & Service Members
 
Trust Exchange and ICS Webinar on Cannabis Banking Compliance
Trust Exchange and ICS Webinar on Cannabis Banking ComplianceTrust Exchange and ICS Webinar on Cannabis Banking Compliance
Trust Exchange and ICS Webinar on Cannabis Banking Compliance
 
Roles.Agents.Navigators.Play.In.Exchanges.Eba.Article.4.1.11
Roles.Agents.Navigators.Play.In.Exchanges.Eba.Article.4.1.11Roles.Agents.Navigators.Play.In.Exchanges.Eba.Article.4.1.11
Roles.Agents.Navigators.Play.In.Exchanges.Eba.Article.4.1.11
 
US Military Veterans Resources
US Military Veterans ResourcesUS Military Veterans Resources
US Military Veterans Resources
 
4th edition veterans resources guide july 2013
4th edition veterans resources guide   july 20134th edition veterans resources guide   july 2013
4th edition veterans resources guide july 2013
 
PPT - What Is A Thesis Statement PowerPoint Presentation, Free
PPT - What Is A Thesis Statement PowerPoint Presentation, FreePPT - What Is A Thesis Statement PowerPoint Presentation, Free
PPT - What Is A Thesis Statement PowerPoint Presentation, Free
 
2022 Procurement Playbook - FEHB- (06/10/2022)
2022 Procurement Playbook - FEHB- (06/10/2022)2022 Procurement Playbook - FEHB- (06/10/2022)
2022 Procurement Playbook - FEHB- (06/10/2022)
 

Mais de Experian

Mais de Experian (18)

Top Regulatory Insights for Fintechs & Financial Institutions
Top Regulatory Insights for Fintechs & Financial InstitutionsTop Regulatory Insights for Fintechs & Financial Institutions
Top Regulatory Insights for Fintechs & Financial Institutions
 
Digital Credit Marketing Best Practices and Trends Webinar
Digital Credit Marketing Best Practices and Trends WebinarDigital Credit Marketing Best Practices and Trends Webinar
Digital Credit Marketing Best Practices and Trends Webinar
 
How Big Data Can Lead to Bigger ROI
How Big Data Can Lead to Bigger ROIHow Big Data Can Lead to Bigger ROI
How Big Data Can Lead to Bigger ROI
 
How Alternative Credit Data Provides Lift in Your Portfolio
How Alternative Credit Data Provides Lift in Your PortfolioHow Alternative Credit Data Provides Lift in Your Portfolio
How Alternative Credit Data Provides Lift in Your Portfolio
 
Credit outlook for Millennials and Gen Z
Credit outlook for Millennials and Gen ZCredit outlook for Millennials and Gen Z
Credit outlook for Millennials and Gen Z
 
Credit Marketing in the Digital Age
Credit Marketing in the Digital AgeCredit Marketing in the Digital Age
Credit Marketing in the Digital Age
 
How do consumers feel about alternative credit data?
How do consumers feel about alternative credit data?How do consumers feel about alternative credit data?
How do consumers feel about alternative credit data?
 
How do lenders perceive alternative credit data?
How do lenders perceive alternative credit data?How do lenders perceive alternative credit data?
How do lenders perceive alternative credit data?
 
Trends in Alternative Financial Services
Trends in Alternative Financial Services Trends in Alternative Financial Services
Trends in Alternative Financial Services
 
4 best practices in digitizing mortgage verification
4 best practices in digitizing mortgage verification4 best practices in digitizing mortgage verification
4 best practices in digitizing mortgage verification
 
Proactively improve reporting access with data accuracy tools and best practices
Proactively improve reporting access with data accuracy tools and best practicesProactively improve reporting access with data accuracy tools and best practices
Proactively improve reporting access with data accuracy tools and best practices
 
Leveraging data, tech and analytics to improve collections
Leveraging data, tech and analytics to improve collectionsLeveraging data, tech and analytics to improve collections
Leveraging data, tech and analytics to improve collections
 
Understanding Gen Z: How will they shape the world of credit and consumerism?
Understanding Gen Z: How will they shape the world of credit and consumerism?Understanding Gen Z: How will they shape the world of credit and consumerism?
Understanding Gen Z: How will they shape the world of credit and consumerism?
 
A First Look at Gen Z and Credit
A First Look at Gen Z and CreditA First Look at Gen Z and Credit
A First Look at Gen Z and Credit
 
Credit Marketing Strategies to Capture Today's Digital Consumer
Credit Marketing Strategies to Capture Today's Digital ConsumerCredit Marketing Strategies to Capture Today's Digital Consumer
Credit Marketing Strategies to Capture Today's Digital Consumer
 
The Future of Collections
The Future of CollectionsThe Future of Collections
The Future of Collections
 
Your Top 10 TCPA Questions Answered
Your Top 10 TCPA Questions AnsweredYour Top 10 TCPA Questions Answered
Your Top 10 TCPA Questions Answered
 
State of Credit 2015: How Does Your State Rank?
State of Credit 2015: How Does Your State Rank?State of Credit 2015: How Does Your State Rank?
State of Credit 2015: How Does Your State Rank?
 

Último

MASTERING FOREX: STRATEGIES FOR SUCCESS.pdf
MASTERING FOREX: STRATEGIES FOR SUCCESS.pdfMASTERING FOREX: STRATEGIES FOR SUCCESS.pdf
MASTERING FOREX: STRATEGIES FOR SUCCESS.pdf
Cocity Enterprises
 
Call Girls in Yamuna Vihar (delhi) call me [🔝9953056974🔝] escort service 24X7
Call Girls in  Yamuna Vihar  (delhi) call me [🔝9953056974🔝] escort service 24X7Call Girls in  Yamuna Vihar  (delhi) call me [🔝9953056974🔝] escort service 24X7
Call Girls in Yamuna Vihar (delhi) call me [🔝9953056974🔝] escort service 24X7
9953056974 Low Rate Call Girls In Saket, Delhi NCR
 

Último (20)

Kurla Capable Call Girls ,07506202331, Sion Affordable Call Girls
Kurla Capable Call Girls ,07506202331, Sion Affordable Call GirlsKurla Capable Call Girls ,07506202331, Sion Affordable Call Girls
Kurla Capable Call Girls ,07506202331, Sion Affordable Call Girls
 
Lion One Corporate Presentation May 2024
Lion One Corporate Presentation May 2024Lion One Corporate Presentation May 2024
Lion One Corporate Presentation May 2024
 
Toronto dominion bank investor presentation.pdf
Toronto dominion bank investor presentation.pdfToronto dominion bank investor presentation.pdf
Toronto dominion bank investor presentation.pdf
 
7 steps to achieve financial freedom.pdf
7 steps to achieve financial freedom.pdf7 steps to achieve financial freedom.pdf
7 steps to achieve financial freedom.pdf
 
Female Escorts Service in Hyderabad Starting with 5000/- for Savita Escorts S...
Female Escorts Service in Hyderabad Starting with 5000/- for Savita Escorts S...Female Escorts Service in Hyderabad Starting with 5000/- for Savita Escorts S...
Female Escorts Service in Hyderabad Starting with 5000/- for Savita Escorts S...
 
Webinar on E-Invoicing for Fintech Belgium
Webinar on E-Invoicing for Fintech BelgiumWebinar on E-Invoicing for Fintech Belgium
Webinar on E-Invoicing for Fintech Belgium
 
Mahendragarh Escorts 🥰 8617370543 Call Girls Offer VIP Hot Girls
Mahendragarh Escorts 🥰 8617370543 Call Girls Offer VIP Hot GirlsMahendragarh Escorts 🥰 8617370543 Call Girls Offer VIP Hot Girls
Mahendragarh Escorts 🥰 8617370543 Call Girls Offer VIP Hot Girls
 
MASTERING FOREX: STRATEGIES FOR SUCCESS.pdf
MASTERING FOREX: STRATEGIES FOR SUCCESS.pdfMASTERING FOREX: STRATEGIES FOR SUCCESS.pdf
MASTERING FOREX: STRATEGIES FOR SUCCESS.pdf
 
In Sharjah ௵(+971)558539980 *_௵abortion pills now available.
In Sharjah ௵(+971)558539980 *_௵abortion pills now available.In Sharjah ௵(+971)558539980 *_௵abortion pills now available.
In Sharjah ௵(+971)558539980 *_௵abortion pills now available.
 
Call Girls in Yamuna Vihar (delhi) call me [🔝9953056974🔝] escort service 24X7
Call Girls in  Yamuna Vihar  (delhi) call me [🔝9953056974🔝] escort service 24X7Call Girls in  Yamuna Vihar  (delhi) call me [🔝9953056974🔝] escort service 24X7
Call Girls in Yamuna Vihar (delhi) call me [🔝9953056974🔝] escort service 24X7
 
Famous Kala Jadu, Black magic expert in Faisalabad and Kala ilam specialist i...
Famous Kala Jadu, Black magic expert in Faisalabad and Kala ilam specialist i...Famous Kala Jadu, Black magic expert in Faisalabad and Kala ilam specialist i...
Famous Kala Jadu, Black magic expert in Faisalabad and Kala ilam specialist i...
 
Strategic Resources May 2024 Corporate Presentation
Strategic Resources May 2024 Corporate PresentationStrategic Resources May 2024 Corporate Presentation
Strategic Resources May 2024 Corporate Presentation
 
falcon-invoice-discounting-unlocking-prime-investment-opportunities
falcon-invoice-discounting-unlocking-prime-investment-opportunitiesfalcon-invoice-discounting-unlocking-prime-investment-opportunities
falcon-invoice-discounting-unlocking-prime-investment-opportunities
 
Female Russian Escorts Mumbai Call Girls-((ANdheri))9833754194-Jogeshawri Fre...
Female Russian Escorts Mumbai Call Girls-((ANdheri))9833754194-Jogeshawri Fre...Female Russian Escorts Mumbai Call Girls-((ANdheri))9833754194-Jogeshawri Fre...
Female Russian Escorts Mumbai Call Girls-((ANdheri))9833754194-Jogeshawri Fre...
 
Premium Call Girls Bangalore Call Girls Service Just Call 🍑👄6378878445 🍑👄 Top...
Premium Call Girls Bangalore Call Girls Service Just Call 🍑👄6378878445 🍑👄 Top...Premium Call Girls Bangalore Call Girls Service Just Call 🍑👄6378878445 🍑👄 Top...
Premium Call Girls Bangalore Call Girls Service Just Call 🍑👄6378878445 🍑👄 Top...
 
Escorts Indore Call Girls-9155612368-Vijay Nagar Decent Fantastic Call Girls ...
Escorts Indore Call Girls-9155612368-Vijay Nagar Decent Fantastic Call Girls ...Escorts Indore Call Girls-9155612368-Vijay Nagar Decent Fantastic Call Girls ...
Escorts Indore Call Girls-9155612368-Vijay Nagar Decent Fantastic Call Girls ...
 
Famous No1 Amil Baba Love marriage Astrologer Specialist Expert In Pakistan a...
Famous No1 Amil Baba Love marriage Astrologer Specialist Expert In Pakistan a...Famous No1 Amil Baba Love marriage Astrologer Specialist Expert In Pakistan a...
Famous No1 Amil Baba Love marriage Astrologer Specialist Expert In Pakistan a...
 
Bhubaneswar🌹Ravi Tailkes ❤CALL GIRLS 9777949614 💟 CALL GIRLS IN bhubaneswar ...
Bhubaneswar🌹Ravi Tailkes  ❤CALL GIRLS 9777949614 💟 CALL GIRLS IN bhubaneswar ...Bhubaneswar🌹Ravi Tailkes  ❤CALL GIRLS 9777949614 💟 CALL GIRLS IN bhubaneswar ...
Bhubaneswar🌹Ravi Tailkes ❤CALL GIRLS 9777949614 💟 CALL GIRLS IN bhubaneswar ...
 
Technology industry / Finnish economic outlook
Technology industry / Finnish economic outlookTechnology industry / Finnish economic outlook
Technology industry / Finnish economic outlook
 
Certified Kala Jadu, Black magic specialist in Rawalpindi and Bangali Amil ba...
Certified Kala Jadu, Black magic specialist in Rawalpindi and Bangali Amil ba...Certified Kala Jadu, Black magic specialist in Rawalpindi and Bangali Amil ba...
Certified Kala Jadu, Black magic specialist in Rawalpindi and Bangali Amil ba...
 

Protecting and Serving Military Credit Consumers

  • 2. 1.46 million active personnel in the U.S. military. http://us-military-branches.insidegov.com/app-question/443/How-many-people-are-there-in-the-US-military  http://www.globalfirepower.com/country-military-strength-detail.asp?country_id=united-states-of-america http://www.nctsn.org/resources/public-awareness/month-military-child http://download.militaryonesource.mil/12038/MOS/Reports/2014-Demographics-Report.pdf http://download.militaryonesource.mil/12038/MOS/Reports/2014-Demographics-Report.pdf Military by the Numbers 86.8% of active duty enlisted members are stationed in the United States and U.S. territories. 49.6% of active duty enlisted personnel are 25 years of age or younger 2 million military children in the U.S., ranging in ages from newborn to 18 years old; 1.3 million military children are school-aged 1.1 million active reserve personnel in the U.S. military.
  • 3. With members of the U.S. military making the ultimate sacrifice – service to country – the government has created several protections to assist with “consumer credit” transactions and their financial lives.
  • 5. Military Lending Act (MLA) – New in 2016 Primary Goal: Protect active-duty soldiers from high-rate loans, such as payday loans, car title loans and tax-refund anticipation loans. • Originally passed by Congress in 2006 and implemented by the Department of Defense (DOD) in 2007 What it covers: • 36% interest rate cap on covered loans to active duty service members • Required disclosures to alert service members to their rights • Prohibits creditors from requiring a service member to submit to arbitration in the event of a dispute
  • 6. New rules were introduced in July 2015 and became effective on October 1, 2015. Compliance is required by October 3, 2016, but rules for credit cards is delayed until October 3, 2017. • Now includes addition of fees paid “for a credit-related ancillary product sold in connection with the credit transaction.” Although the MAPR limit is 36%, ancillary product fees can add up and exceed the MAPR limit. • Includes a “safe harbor” from liability for lenders who verify the MLA status of a consumer. • Lenders need to identify who is in active military duty at origination, obtaining information directly or indirectly from the Department of Defense’s DMDC database. New MLA Regulations
  • 7. “When I drive down a strip outside a military installation and count 20 fast-cash lenders in less than 4 miles, that’s not a convenience, that’s a problem.” – Holly Petraeus, CFPB Assistant Director
  • 9. Primary Goal: Offer an umbrella of protections to military personnel whose service duties conflict with the financial obligations they have as civilians. • Originally called the Soldiers and Sailors Civil Relief Act when first passed in 1918. • Got its current name when rewritten and expanded again in 2003 What it covers: • An interest rate cap of 6% on loans military service members incurred prior to becoming active. Applies to any charges – including credit card debt, service charges and renewal charges or fees – except bona fide insurance. Federally guaranteed student loans were added in 2008. • Accounts of the service member, or joint accounts of the service member and the service member’s spouse, are additionally eligible. To receive the interest rate reduction, a service member must request it in writing and include a copy of his or her military orders. Servicemembers Civil Relief Act (SCRA)
  • 10. Best Practices to Serve Military Consumers in Financial Services As a lender, you must adhere to SCRA and MLA regulations, so ensure you have systems and governance in place to manage compliance. Consider adding pages to your website, providing information on SCRA and MLA, so military customers understand their rights and how to best work with you. If you offer additional military benefits, communicate these. Many lenders offer military rebate programs – don’t be shy in advertising these discounts. 1 2 3
  • 11. To learn more about how Experian can help you best service you military consumers and adhere to regulations like MLA and SCRA, visit experian.com/military © 2016 Experian Information Solutions, Inc. • All rights reserved. Experian and the Experian marks used herein are trademarks or registered trademarks of Experian Information Solutions, Inc. Other product and company names mentioned herein are the property of their respective owners. This information is for educational purposes only. It is not intended to be nor should it be relied upon as legal advice. If you have questions about the information contained herein, you should consult your own legal and compliance departments.