Q: So, a credit union writes, “We don't make any loans with interest rates as high as 36%. The credit union's highest rate is 18%. Do we still have to determine if a person is a covered borrower?”
A: Yes, unless your credit union complies with all the requirements and restrictions of the MLA and the regulations. In addition to the MAPR limits, the MLA and its regulations contain other requirements and restrictions as we discussed this afternoon. A credit union that does not comply with those requirements and restrictions runs the risk of non-compliance by lending to a covered borrower.