Compliance: CUNA updates MLA fee comparison spreadsheet

CUNA compliance staff has updated its Military Lending Act (MLA) fee comparison spreadsheet for the second quarter of 2018. The resource can be found in CUNA’s Compliance Community under the “Compliance Resources” tab, and under the “Resources” tab in the MLA topic in CUNA’s e-Guide.

CUNA launched this resource in October to help credit unions determine which fees are considered “reasonable and bona fide” under the MLA. Under a safe harbor in the MLA rule, a credit union may exclude a Bona Fide credit card fee from the military annual percentage rate (MAPR) if the fee is considered “reasonable.”

This means the fee must be less than or equal to the average fee for the same or similar product charged by five separate card issuers, that each have at least $3 billion in outstanding credit card balances at any time during the three-year period preceding the time the average is determined.

 

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