Amended Military Lending Act goes into effect on October 3; CFPB releases updated exam procedures

Today, September 30, 2016, the Consumer Financial Protection Bureau (CFPB) identified the updated exam procedures it will use to audit lenders who do business with military personnel. According to CFPB Director Richard Cordray, “[t]he updated exam procedures…will help ensure that servicemembers and their families are dealt with in a fair and safe manner when attempting to access credit.” Specifically, the requirements prohibit interest rates above 36 percent MAPR, mandatory waivers of consumer protection laws and mandatory allotments.

In its press release, the CFPB vows to strictly monitor financial institutions, their compliance programs and their “overall efforts to follow the rule’s requirements.” Evaluating everything from staff training to loan implementation, the CFPB will use the new rules to prevent substantial consumer harm. The updated Military Lending Act rules go into effect on October 3 for creditors. Credit card companies must be prepared to comply with the new rules by October 3, 2017.

Pawnbrokers make up a segment of the financial services industry that will be affected by these new rules under the Military Lending Act. Attorney, Jackie Mallett recently hosted a webinar discussing the amended rules and how they will affect the pawn industry. View the webinar in its entirety here

Compliance Management, Consumer Lending and Services, Depository Institutions, Fair Lending, Federal Regulatory, Non-Depository Institutions

David Stein authors MBA’s social media and digital advertising compliance guide

David Stein, of counsel and chair of Bricker & Eckler's Banking & Financial Services group, authored the “Social Media and Digital Advertising Resource Guide,” which was recently published by the Mortgage Bankers Association (MBA).

The resource advises financial institutions “how to manage the challenges posed by digital marketing and advertising of residential mortgage products and services,” according to the MBA. The guide examines the statutory and regulatory background related to mobile and digital marketing, and provides draft policies and procedures.

The online resource guide is available for purchase on the MBA’s website here

Compliance Management, Consumer Lending and Services