ABA yesterday issued a bank members-only staff analysis of the Defense Department’s final rule under the Military Lending Act tightening restrictions on lending to service members and their families. The analysis provides a thorough overview of the rule, including what kinds of credit and borrowers are covered, what disclosures must be provided and how a borrower’s military status may be verified.
The analysis also includes in-depth detail on the rule’s “military APR,” an all-in APR capped at 36 percent that differs from the definition of APR under Regulation Z, and covers penalties associated with the final rule. For more information, contact ABA’s Nessa Feddis.
