New and Revised Policy Templates for August 2015
These new and updated products were in response to the U.S. Department of Defense’s News Release entitled “Department of Defense Issues Final Military Lending Act Rule” dated 07/21/15 that better protects service men and women from predatory credit practices by expanding financial protections provided to service members, and helping ensure military families receive the consumer protections they deserve. This rule applies the protections of the Military Lending Act to all forms of payday loans, vehicle title loans, refund anticipation loans, deposit advance loans, installment loans, unsecured open-end lines of credit, and credit cards. To assist industry in complying with the MLA, the new rule will go into effect Oct. 1, 2015, and have a staggered compliance dates.
As a reminder, the complete contents of the Short Term and Small Dollar (Payday) Loan Program Policy Template are included within the Consumer Loan Policy Template as Topic 14.
The update to these products is in response to the CFPB’s Press Release entitled “CFPB Finalizes Two-Month Extension of Know Before You Owe Effective Date” dated 07/21/15 that announced a final rule moving the effective date of the Know Before You Owe mortgage disclosure rule, also called the TILA-RESPA Integrated Disclosures rule, to October 3, 2015. The rule requires easier-to-use mortgage disclosure forms that clearly lay out the terms of a mortgage for a homebuyer. The CFPB issued the change to correct an administrative error that would have delayed the effective date of the rule by at least two weeks, until August 15, at the earliest.