Military Lending Act (MLA) NCUA Q&A – Reg. Z $54,600 Threshold

Compliance > Lending > Service Members > Military Lending Act
Q:  Credit union writes that, “You mentioned an exclusion for coverage of credit in excess of the $54,600 threshold.  Please explain the $54,600 threshold.”
 
A:   Under TILA, most non-mortgage consumer transactions for more than $50,000 are excluded from TILA and Regulation Z coverage.  TILA requires the Consumer Financial Protection Bureau to adjust that threshold figure annually according to changes in the consumer price index.
 
The 2016 threshold is $54,600.  Because the amended regulation excludes from MLA coverage most credit exempt from TILA coverage, the $54,600 cap also applies to the MLA.  An exception to that rule is private student loans.  They are covered by TILA and the MLA even if they exceed the $54,600 threshold.
 
 
 
 
 
 
 
ADDITIONAL INFORMATION – This Q&A was included in the NCUA’s June 2016 webinar entitled “Preparing to Comply with Regulatory Changes under the Military Lending Act.”  To listen to the audio and view the slides, interested parties may find that information here:  https://event.on24.com/eventRegistration/EventLobbyServlet?target=registration.jsp&eventid=1186523&sessionid=1&key=72023B4705907CDD0D194100B89E5D11&sourcepage=register
 

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