NCUA released Regulatory Alert 16-RA-04 providing guidance on complying with the changes to the Military Lending Act requirements. The guidance, Complying with Recent Changes to the Military Lending Act Regulation, provides a good overview of the changes, and the steps that the credit union will have to take.

Along with an overview of the changes, the guidance includes how to identify a covered borrower, Military Annual Percentage Rate (MAPR) limits and the effect of fees, required disclosures – both written and verbal, and other restrictions placed on credit extended to covered borrowers.

Credit unions should review the guidance, and work with its vendors to ensure that loan agreements comply and the MAPR is not exceeded for covered borrowers.

The effective date for compliance is October 3, 2016 with credit card requirements on October 3, 2017.