Military Lending - 11th Hour Checklist

Recorded on September 28, 2016   |   With Jack Holzknecht and Kelly Owsley

Military Lending - 11th Hour Checklist

With Jack Holzknecht and Kelly Owsley
  • 1 Video
  • 3 PDFs
  • 2.0 hrs
Course description

ICB Credit: 2.5 CRCM


The DOD recently amended its Military Lending Act regulations primarily for the purpose of extending the protections of the MLA to a broader range of credit products. The revised regulations also revise several defined terms. add two safe harbor methods for determining if an individual is a covered borrower, provide details on the proper calculation of the Military Annual Percentage Rate (MAPR), and add clarification on the content of disclosures and the scope of special limitations. While many lenders have avoided offering covered loans in the 10 years the MLA has been around, the scope changes in the new rules will make avoidance nearly impossible.
Compliance is mandatory, for the most part, on October 3, 2016. Before consummating the first covered closed-end loan or establishing the first covered open-end line on October 3, 2016, all creditors should have in place a standard operating procedure to ensure compliance with the Military Lending Act.

This information-packed program provides last minute preparation for the October 3, 2016 mandatory compliance date. This program also points out MLA problem areas and proposes practical solutions to those problems. Participants receive a detailed manual.

Upon completion of the program, participants should understand:

Upon completion of the program, participants should understand:

  • How to determine whether a transaction is covered or exempt;
  • How to determine and verify which applicants are "covered borrowers," including use of:
    • The DoD database;
    • Credit reports; and
    • Other methods
  • How to identify dependents of a covered member;
  • Required disclosures, including:
    • Content of the disclosure;
    • Timing of the disclosure; and
    • Written and oral delivery;
  • How to calculate the MAPR and ensure compliance with the 36% limit on the MAPR:
    • Complying with the 36% limit is a bigger challenge than it first appears;
    • Alternative calculations if loan origination and/or core accounting software is not up to the task;
      • APRWIN software;
      • Calculator, pen and paper;
  • Limitations on creditor acts or practices:
    • Which of the limitations apply to financial institutions?
    • Clarification of the prohibition on taking an account or a certificate of deposit as collateral;
  • Implementation issues, including:
    • The need for policies and procedures;
    • The capabilities of loan origination and core accounting software;
  • Recordkeeping requirements;
  • The effective and mandatory compliance dates; and
  • Penalties and remedies.

The program is designed for loan officers, compliance officers, loan processors and clerks, auditors, and everyone else with responsibilities related to consumer lending. The whole consumer lending team needs to participate in this 11th Hour program

Course Curriculum

Military Lending - 11th Hour Checklist
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Jack Holzknecht and Kelly  Owsley
Jack Holzknecht and Kelly Owsley
Compliance Gurus

Jack Holzknecht is the CEO of Compliance Resource, LLC. He has been delivering the word on lending compliance for 39 years. In Jack's 34 years as a trainer over 125,000 bankers (and many examiners) have participated in his live seminars and webinars. Jack's career began in 1976 as a federal bank examiner. He later headed the product and education divisions of a regional consulting company. There he developed loan and deposit form systems and software. He also developed and presented training programs to bankers in 43 states. Jack has been an instructor at compliance schools presented by several state bankers associations. He developed and delivered compliance training for the FDIC and OTS for ten years. He is a Certified Regulatory Compliance Manager and a member of the National Speakers Association. He is also a "BOL Guru."

Kelly M. Owsley, CRCM is Director of Training Services for Compliance Resource, LLC. Kelly's career in banking began in 2000. Since then she has worked for financial institutions ranging in asset size from $250 million to $3 billion. Kelly has worked in numerous areas of the financial services industry including retail branch management, lending, product development and training. In addition, Kelly spent three years in a training and development role with CUNA Mutual Group servicing the largest credit union in the United States. Most recently, she served as the Vice President of Compliance, BSA Officer, and CRA Officer for a community bank in Kentucky where she was responsible for implementing and training all compliance related topics. Kelly holds a Bachelor of Science degree in Accounting from the University of Kentucky and is a Certified Regulatory Compliance Manager.