three Quick Notes For Tuesday

September 13, 2016 at 8:31 am Leave a comment

I’m about to leave for the Association’s Annual Legal & Compliance conference, at the Turning Stone Casino, but there are Three things I want to give you a  heads- up on.

First, NCUA Yesterday released a letter reminding credit unions that guidance was issued on August 26 intended to clarify questions surrounding Military Lending Act Regulations that take effect on October 3rd.  I would make fun of NCUA for coming out with guidance on guidance but your blogger must shamefully admit that he actually didn’t realize that this guidance was even issued in the closing days of summer.

The MLA regulations are a big deal. As I have explained in a previous blog, almost all consumer credit transactions subject to Regulation Z  involving military personnel and their dependents will now be subject to greatly enhanced consumer protections, including a Military APR  interest rate cap of 36%.  Since this APR is calculated differently than a traditional APR under Regulation Z,  this creates yet a new level of complexity when it comes to consumer lending.  You may not serve many members of the armed forces but remember  since  the regulation now  applies to so many different products all credit unions should put procedures in place for identifying members to whom this regulation applies.  Frankly, I  think the guidance creates as many questions as it answers but I will let  you hard-core compliance folks out there decide for yourselves.

Is This The Credit Card Of  The Future?

Everything I have read about millennials is that they are debt averse so take the time to read this intriguing article in the New York Times explaining why millennials are so interested in a new credit card being offered by J.P Morgan Chase with an annual fee of $450. Are they crazy?  Or just crazy like foxes?

You Have To Know When To Fold Em

Finally if you find yourself tempted by the Turning Stone’s poker tables tonight remember: Those who chase straights and flushes arrive on planes but leave on busses.

On that note, I hope to see you at the Turning Stone, if our paths cross please be sure to say hello! I will be back on Thursday.






Entry filed under: Compliance, Regulatory. Tags: .

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Authored By:

Henry Meier, Esq., General Counsel, New York Credit Union Association.

The views Henry expresses are Henry’s alone and do not necessarily reflect the views of the Association.

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