Predatory Lending Practices & How to Avoid Them

It is now the top of the hour We welcome you to our webinar This learning opportunity is brought to you by the Military Families Learning Network And the Personal Finance Concentration Area We hope that you will join us in Facebook and Twitter Please join the conversation online The Personal Finance Concentration Area works with financial planners who work with military families You can find resources from today’s session at: There you’ll find copies of the PowerPoint slides as well as other online resources we will discuss today Please join me in welcoming our presenters management specialist for Rutgers
Cooperative Extension has been a We are happy to have both of these great
speakers on board Now let’s let them begin thank you welcome everyone i’m glad you’re here
today. This is a very important topic a very timely topic It is is pretty much hot off the press so it’s definitely a very teachable moment. I’m Barbara O’Neill and I will be doing part 1 Here are the objectives for my section We’re going to talk a little
bit about what is predatory lending then we will identify some red flags of predatory lending and talk about various types of high-cost loans like payday loans. We will discuss subprime lending And provide resources for further
information I encourage those of you that work with
two monitors to open URLs in a second window And we will be putting resources in the chat window and also posting them online along with other materials on We wanted to cover this topic now because this month included military consumer protection day Some of you may have been involved in that I was not able to participate as
actively as I would like to but I’m sure many of you did and if you didn’t see it here is the mission statement for military consumer protection day. It’s
really aimed at helping people get information to reduce the incidents and protect
entities and they had a website that you can visit to get more information Here is a question…
what predatory lending practices
concern you and your clients the most? Please answer in chat I’m seeing rent-to-own, online lenders… comcerms that have to do with online payday lenders, payday loans, car title loans… refund anticipation loans, high-interest
loans… refi advertisements, closing costs… overdraft protection advertisements… a lot of what you mention in chat we will talk about And we will talk about about the applications to military families Well what is predatory lending? Here are definitions and there’s a link there that gives you some background information but let’s look at the tell tale signs so that people can recognized regardless of how it’s defined but more important thing is
that people can recognize it and be able to avoid it We’re talking about high interest loans you know much higher than normal market interest rates would
dictate, outrageous fees of all types on the front end and on the back end. These people are selling products very high pressure
tactics unaffordable repayment terms of getting loans that they simply cannot
carry income and assets and then the
collection tactics are harassing people and then deceptive advertisements like fill in the blanks loan applications whereby people sign something and then things get inserted later All those things fall under the term predatory lending.
Some of the target populations are people who are vulnerable financially in all aspects.
Like the elderly who maybe no longer have the decision-making capacity in their later life And certainly people who are inexperienced are vulnerable, people who are young people who are desperate they need
immediate cash and perhaps they have weak credit records so they’re not able to access cash and sometimes it’s people who were
living beyond their means Some limitations relate to education, formal and informal education And here is a formal definition Service members may be more vulnerable as they may have more mortgage transactions than other people do Red flags include constant offers to refi and of course every time you’re refinancing mortgages you’re paying fees Mortgages that have a very high debt service to income
ratio and a very high loan-to-value ratios so you’re borrowing almost as
much as the house and then there’s the whole thing ever reverse redlining learned about redlining and some kind of
course where lenders take a red sharpie map and more red line on and say we’re
not going to lend people that are within this red line well reverse redlining is
the opposite its other red line and they will lend to people that live in certain neighborhood
but of course they’re charging high rates above their capacity to pay.
There are mortgages that have a lot of what they call loan packing where
there are a lot of fees and insurance and everything else they can pack in Have any of you should add clients who had to deal with this? Please share in chat In chat I’m seeing a lot of yes answers, people who were given loans for more than they could afford… a 40 year mortgage … two mortgages… You see a lot of that with predatory mortgages … people are given mortgages they can’t afford What about other predatory lending practices on the
consumer loan side non-mortgage debt, things like payday loans … credit repair companies… these are out there These types of things really overcharge people a lot of money Payday loans may be referred to as cash advance loans check advance loans… People people are borrowing against their next paycheck and that’s how they got their name so you basically write a post dated check post dated meaning a check with a future date on it typically 2 weeks And the amount you’re writing the check
for is the loan plus the lender’s fee the fee is either a percentage of the check amount or a flat fee they can schedule a lot of the land
fills state regulations that might be So you’re paying a fee to use the money over a two-week period and the check isn’t cashed for up to 14 days Many payday lenders have a 14
day period so you’re paying a typical charge that might be 15 to $20
as a fee for $100 loan that you’re getting so for example you might write a
check for 115 to borrow 100 dollars it’s funny when I explained this to my class because payday loans are illegal in our state so we don’t have the stores like some other states do So people are kind of incredulous like this in New Jersey because it’s not something we’re familiar with If you write that $115 check to borrow $100 for 14 days and if you do the math the $15 fee is 390% APR Then after 2 weeks go by people have 2 choices Redeem or extend. Redeem by bringing in the $115 Or extend it with another loan and do that
whole process again So if it rolls over it’s $15 a pop if you do that you paid $60 for $100 And if you do 6 rollovers at $15 a pop you
paid $105 to borrow $100 It doesn’t take very long for the finance charge to be higher And that’s just real problem for people who maybe hadn’t realized that is how it worked The payday loans often they call the charges a fee rather than calling the charges “interest” Although it really is interest If the loans aren’t charging interest I don’t know what they are charging They may call it a different thing but it’s
just like interest Fees that seem small like $15 are going to add up it’s a very very high interest rate Here is a true story She got into a bind and a year later she had paid $1,220 in fees And she still owed the $200! The question is so what can they do But that’s a pretty scary story about how fees and rollovers kept adding up Here are some alternatives well for some people if you have a steady income you may be able to get a small consumer loan
either through a bank or credit union perhaps it could be secured with a bank
account another option is to work out a payment plan with the money… to pay some bills perhaps you can work something
out with perhaps with the assistance of a non-profit credit counseling
agency short term loans are not anywhere near that even the interest I read an article but even some community banks are offering payday loans I mean they don’t call them pay day loans because of the negativity
associated with that word but they’re basically doing them Another option would be a credit card cash advance and then obviously the costs
associated are high research studies that came across my
desk I thought might be kind of I saw research that said that people who
live in states that allow rollovers are more likely to use pawn shop loans
as well and the researchers theorize that
the problem is that if you have the rollover then you get further in debt and
after a while even payday loans are going to max out and you
still need to supplement your income to paid bills or to try to make payments on
the payday loans people resort to pawn shop loans Some people may use many of these alternatives financial services sector products may
not just one and in fact many of them are set up in some locations to almost
be like a one stop shop where you can visit the pawn shop payday loans
check-cashing have them right in the same store for example The car title loans means you give the lender your car title to get a loan and if you cannot pay the car is repo’ed and the lender gets to keep the amount
the car sells for so for example if you have a car that’s worth $2,500 and you
owe the lender a thousand and you’re not able to make those payments that lender
is going to pocket the difference the pocket there and so they make money that way Car title loans are particularly insidious
because it’s just stripping away equity out of an asset that may be one of the few assets that you have The loan is typically made for 25 to 35% of the value So if you had a car it’s worth $2,500 lenders probably gonna make a loan of around $700 and interest rates are high 20% + for 30 days 20% for 30 days Typically lenders want a clear title with no loan The cars tend to be older but in decent shape And the lender takes a key as well as the title to the car Some of the pros and cons are there’s no credit check Few personal questions are asked about
income or assets The wait is typically very short for the money Disadvantages include high interest, ease of repossession and the fact that people could lose the equity Anyone who wants to do this needs to have money coming in 30 days to be able to pay it off This is an expensive way to borrow And people can end up spending more than 10% of their refund to get the money weeks sooner- if you’re e-filing you’re
gonna have a pretty rapid turnaround They charge for rapid refund anticipation loans and then refund anticipation checks racks and of
course the better option because we want to not just tell people these things
are bad but also to say well what else could you do where can you go There are other options on the screen About 10% of American workers have no formal banking relationship and then we’ve got others who are either unbanked or underbanked … underbanked means it there is some type of banking relationship but they’re still going to alternative financial sector as well so you got a
check-cashing outlets charge high fees to cash checks and that includes
government checks payroll checks personal checks sometimes they are charging as much as 25 to cash a $500 Social Security check the federal government is considered the
safest type of check that could be issued its backed by the federal
government and yet they’re pretty high P that are costing people just day and of course it to check attention at
which not only are charging fees she acts but they’re also issuing money
orders then once people get the money care they need some way to make payments
and so they’re paying both ways they’re paying to cast you have money orders to
make payments so the charges i’ve seen reports that say anywhere from
1 percent to 20 percent of the check-and-balance typically of course
the personal checks have the highest East because you know there’s a
government backing approaching that’s written that Shaq average cost can be
between two and six percent a lot of this depends on state again the appeal
to the unbanked households one of the fastest growing IT services rather and
then one study that I found was a family that was paint $396 cash a check and get
6 money orders and that’s just one there’s problems sure many of you and probably points too
much more used to enhance them they’re so again it kind of goes back to where
can people go so I was in New York last week that she and some of the folks in
our Learning Network know this that I our financial education program were
veterans in our records that program which is training veterans were careers
in agriculture and landscaping and politics and they also have a fish farm
it’s pretty interesting operation it’s actually funded with the leadership
money always dad actors that provided some of the waters around Newark and
fish that are growing on this fish farmer exchange or this that are needed in the rivers and
anyway working with the FBI agent who’s running
this program and it became apparent that a lot of the participants in the program
were unranked and were finding it very difficult you get a banking relationship
because they’re basically with paycheck to paycheck and when I did the program
last week I asked if any of them knew that our state state mandated you know
Jersey not one person knew that we have a state as do many stage a nation that
mandates a challenge and moderate-income persons and it requires you know you can
get it down to $1 you don’t need to hold you know $100 to avoid fees you take $80
but it’s very conducive to people have a rare and very erratic incomes and
balances nobody knew about it so make sure your your folks know that there is
a statement and channel probably year the banking should have information
about that captured credit union where they work their church perhaps an
electronic transfer cans which many people when they have recurring federal
benefits for example like even stock markets forecasting a personal check if
they are being and they have it in me just another $20 to get through a couple
J’s supermarkets she will generally cash checks again you may have to be part of
their program that you sign up for you get a check can see and maybe you think
of others I’m just anybody have any other alternatives that are good
alternatives to check cashing possibly refilled debit card again you
have to look at the the fees associated with some of those prepaid debit cards
that you can get in some of the stuff right now I’m noticing coach saying our
Walmart will cash payroll check up to $1,000 $3 Walmart is an example where she can get
money orders at the post office as well and they’re going to do that military
changes to cashed checks ok so the bottom line is there’s a lot better
options than these financial services okay and then pursue advanced de Mon
state and he’s at the ads that you see you know we’ll give you a loan no
questions asked tell you to call a nine hundred-number department to be paying
if you may or may not get along you probably won’t see these are actually
scams phone calls 900 numbers and the key messages did you tell people you
don’t want to borrow money if you have to pay a fee not granted there are some
reputable loans with these it is you’re talking a modest applications or
something like that that’s one thing indicating that is why and who are
coming from a reputable source you really got a questionnaire and of course
get every thing that is presented orally in writing chance to check it out okay and then
we’ll have to find shops and shops people have items they bring it to the
shop the porn ticket generally most state laws are pretty regulated is
obviously don’t want pawn shops 2d again you for either illegal or stolen items
so typically there’s a lot of information that’s what it terms of the
loan contract the name and address of the customer what the item numbers
attached amount of the loan maturity date and announced today page you redeem them so all that
information has to be disclosed in these are the typical items of value that
you’ll see watches jewelry televisions electronic
equipment chambers perhaps firearms again state specific laws related to
that but those are some of the general character and then of course what
happens becomes the property of pawn shop
usually there is grace period again closed in the contrary might be
relaunched most states will require the point broker to notify the customer
before item goes into default situation / it’s supposed to be returned to the
customer boat research shows that rarely happens in
practice you know that again the item no value comes back to the person and rage
again I saw a range in some of the articles and then I read anywhere from
almost 25% and again it’s like the other types of debt I was talking about at
first two cautions but if you start looking at it on Apr basis the costs are
all often as high a two hundred and forty percent based on brokers also have
additional each so they’ll charge storage either Georgia insurance the
average loans are usually $5,700 10 chip Italy again it’s a percentage of the
retail because obviously the lenders want to have some equity in these items
if they do have to sell them themselves they they don’t want you know he just
maxed out there they were so you’re not gonna get the fall down you gonna get a
percentage and then another common when we see is rent to own lease typically
need some of them are monthly and at the end of each rental period whether it’s
weaker Mon you have a choice to end either continue with the leash and
continue to make the payment and continued item or return the merchandise and then
you have no future payments but again it depends on the specifics of the contract
by NetBeans IDE is that there may be a lot of additional detail typically a the
periods are 18 to 24 months so you see a lot of them and he would be eighteen
month period FTC information actually about that and
it can be much like one shops you gonna she items to add have some value chats
to them the electronics computer equipment furniture things that are
difficult to people who people to buy out of paychecks they’re kind of big
ticket items but also items that maybe people want to have immediately and
they’re not willing to wait till why do people news Rancho well lo weekly or
monthly payments no down payment as you sometimes have on items no credit check
as you are using a credit card and then the big one for a lot of people is to
quickly access you know you saw a few documents and an item that would
otherwise take you a period of time to save up for our households to finance
you can get quickly and then of course the pitfalls are the cost it’s an
extremely high wage costs way to buy fish and chips you’ll pay three to four
times the cash purchase price and another thing is that you can possible
repossession as well little regulation to protect and their
comparison here between 2001 credit contracts you know if it’s a rent to own
your leasing or renting the IDA your pain to use and then when you’re
finished using it you don’t have to pay any more but if you do make all the
payments on the item seventy eight weeks it is a long time people living on the
financial edge should be able to make payments on
things because very often again there’s no emergency find things happen in life
and people sometimes get behind versus credit contracts your person purchasing
the item that monthly payment the APR is all still down and then of
course again you know the ownership when you’re paying in-state here’s a comparison where somebody might
be a city television and you’ve got different options you know you can get
it through the phone it might be $13 a week for seven and eight weeks and the
total cost might be in excess of $1,000 and that’s assuming that is no other
fees attached to it as well that’s just me doing the math on that page and other
way to do it would be to do in instalments there and obviously the
payments are a little bit higher but your payment period you know is its last
unit came as much as being in 1998 Apr and then the other way to do it is just
sage and maybe this television only cost $250 and immediately once you save that
money and so it’s a fraction you know it’s less than 5% of this example and
then here’s another example very much like the shops over there may be some
additional chance to pay day loans it’s not just the pain in the rain check it
and maybe delivery fees and possibly people were late they relate piece maybe
they were so late that they had to get it reinstated there’s a reinstatement
fee and a re-delivery fee if they took it back and have to get back to you so
you can spend actually a lot more than just the amount of pain and China never
reaches this example hundred-point channels so it can be alternatives
because again it’s not enough to just a bad what can you do you can say the $14 we
can purchase the television possibly if you really needed the television you
could get a family members to make a loan and then pay them back to $14
paying a whole lot less you have it immediately rather than saving you can
put it on a bank card and again the payments will be lower or store credit
card like another option and then of course there’s always that needs versus
wants question do i really be decided and are there cheap and it actually can
find something in the thrift shop but scheck and he ok so my next question is
have you had any qualify and credit scoring on mortgage loans and maybe just
like that scenario and so while you’re typing I’m just gonna finish up with a
few points lie about subprime lending that church and what that news subprime is lending to record so they
typically have a low FICO credit score median 667 swanee was maybe they have
hijacked maybe have no credit history they haven’t done anything wrong they
just haven’t used it and they don’t qualify for conventional and again gonna
pay the highest rates and it’s estimated that about 30% us’ population is at it
again characteristics of subprime loans is a
wide variety of lending practices but you’re gonna see interest rates
obviously higher than the Prime raged risk-based pricing where you might have
cheers for people that fall within certain credits courtiers pace interest
rates and again most poor credit histories and chief subprime lending in all types of
Egypt mortgages home equity loans credit cards car loans and the key
differentiating characteristic is that right tiers based on credit schoolers
and that’s what they do and you would wrap up my shit action you want to avoid
winners who do any of these settings tell you to falsify information pressure
you to borrow give you loans more than you can afford to pay back failed to
disclose the terms tell you to sign blank forms or won’t give you copies of
signed documents big red flag and then we always had her webinars with such a
way so I can simply take away show Michigan people can barter way Energy
Act most lenders reputable their predatory lenders but the predatory
loans to have very high interest he’s sometimes teach can exceed the amount
that you borrow people who are vulnerable our target
markets I hope I’ve shown you that many lower-cost alternatives available people needed shot and again it’s
something shelves too good to be true it probably is and I think at this point
we’re gonna turn it back over to very good and its see you need to get slides and yeah they just did III I saw that my era was going to die
figured it was time for you so I think you’re probably just working on that now ok maybe not here yes yes that’s what I was doing and i
know now here we are ok now we’re ready good morning everyone what I’d like to do today is to talk to
you about the military Lending Act and talk about primarily be active get to the
objectives in a moment what they want to cover before I started was just the how
we got to where we are now starting with this this one picture here the payday
advance support our troops it’s it’s interesting how these entities have
congregated around us our military installations and I’m sure your you are
more than aware they had and how they tend to have some kind of affinity
marketing attached to them where they want to appear to be military friendly
the law itself very Lending Act was put in place in 2006 and the initial rule of
law was established in 2007 and it had very limited application and only
covered limited definitions of payday loans vehicle title loans and refund
anticipation loans we have found since then there’s that creditors have changed
their products and other products are now being seen as more problematic and
so there’s not as clear defined field of the predatory we saw is problematic back
in 2007 today in San want to cover the military
Lending Act and the protections that are included in the air and then to find the
credit that is currently covered by the rule that implements the military
landing describe how this revised rule will and then just to cover some
important points to impress upon consumes so first of all let’s cover the
military Lending Act here the areas I’m going to cover what and who are covered specifically from the standpoint of the
law then the limits rich districts to protections that are covered in the law
the disclosure railing with racing that is included in military Lending Act how
the DoD has rule-making authority the consequences of this law and its
relationship to other law though what and who are covered the what covered in
the law is credit as defined by the Department of Defense so the department
has considerable latitude in its rule-making authority to define the
credit that is covered by the law it tried that do the kinds of are not be included in
the material in again and those on board and purchase money loans such as car
loans other thing that is specified in the law is who’s covered and it’s
basically active-duty service members to include reservists or on active duty 30 days or more and their family members
as defined in the years go ahead I am the any questions as we go along
otherwise I’ll just continue to proceed through through the slides are sluts
restrictions protections for me the most prominent one is a 36 percent APR limit
on credit covered by the rule and the interesting thing is this includes all
fees and DOD gets to define what the fees are and the sale of credit products
at the time alone so in those circumstances where lenders to find
their their conscience fees raised interest those were included and where
there’s situations where there’s some packing those circumstances are also
included and this detection is called the military ATR or
matr restrictions that go along with the law there’s a restriction on refinancing
rollovers loan flipping there are restrictions on use each bank accounts
ACH EFT to bank accounts to secure loan and vehicle vehicle titles to secure the
loan there’s restrictions on the use of
allotments and also on prepayment penalty edition in addition to these
restrictions thereof prohibitions on waiting stre rights on mandatory
arbitration and on other onerous legal notices that might be included in the
contract ties primarily to the Truth in Lending
Act disclosures but it does say that the military Apr needs to be disclosed and
that interestingly the disclosures need to be given both in writing and orally
will talk about how we how we advise creditors to administer these
disclosures and I get to the rule making authority as they said DoD has
the authority to define credit also creditors and the feet we don’t do this
alone we have required consultation from the other regular regulatory agencies
have listed them their fees are primarily the enforcement agencies as
well for any rule that we produce recently the the law was changed in it
also requires that we review it every two years the law first thing is that the the loan
is considered null and void at inception if the creditor violates the law second thing is that the bar where
retains a right of private action because there’s no mandatory arbitration
of the law does actually specify what the private right of action is that
includes the opportunity get punitive damages as well as recouping the charges
that were applied against the long the law also prescribes the possibility for
criminal consequences for a creditor who egregiously violate the law and then in relation to other loss primarily
state laws it says that the military Lending Act takes precedence over state
laws unless the state law provides better protection but also states that
state law will cover and protect service members and their families inside their
borders regardless of their legal status terms of their residence DOD rule this role was put into it was
published the 21st of this month and it’s a sizable departure from the
previous rule and I want to cover these aspects certainly to credit the
creditors covered what exemptions we’ve created to the military and an APR
primarily for the benefit of the consumer exceptions to restrictions
again for the benefit of the consumer disclosure process that we’re striving
for creditors they can know to some lending and the military Lending Act
disclosures together the creditors responsibilities and then most
importantly when this thing actually effective and when will creditors need
to comply credit has gone from very limited definitions
of payday vehicle title and refund anticipation loans to all credit defined
by the Truth in Lending Act set for those things we were talking about
excluded by the law so that means and includes all payday loans of vehicle
title loans all tax refund anticipation loans tomlin’s installment loans open and lines of credit and credit
cards workers all providers of credit and her actions the 10th create a definition that has no
loopholes no ways of creditors skirting around the definitions provided as long
as they’re covering providing some kind of credit that’s covered by the Truth in
Lending Act we did provide to the exam actions from the MapR to facilitate the
ability of creditor reasonable appropriate credit service members and
they are for credit cards where fees as long as trick considered bona fide those
kind of either general charge for credit cards and if those bona fide fees are
considered reasonable I won’t go into detail on the way that the rule defines
the criteria for reasonable but it provides a criteria that creditors can
use to make sure that their credit card keys can be exempt in a state don’t
defeat don’t fulfill the criteria then they are included in the M A R and could
considerably increase the D effective APR and cause them to be outside of the
ability or up outside the limits of the of the world we created a limited carve
out of a fee of no more than $20 once per year for a loan that is currently
being provided by the federal credit unions called payday alternative loan
this rule these loans are made under the rules established by the National Credit
Union Administration and they are also covered by the federal loan limit or eighty arlen that
effective on federal credit unions so there are limitations already
established in another federal law and so we have in in a way of creating
comedy with that law allowed for small dollars to the generated under that
separate federal wall outside of the military and the ATR let it be made to the restrictions and these are
basically so that we don’t impede service members obtaining beneficial
types of credit the refinancing restriction has been limited to pay day
loans so that in the event that a service member wants to get a higher
costs higher interest rate loan refinance there’s no limitation that is
closed upon the creditor from doing that establish the bank accounts can be used
to secure loans that are underneath the MapR no greater than 36% and this had been
established in the initial regulation and we have not changed he said the
vehicle titles can be by depositories for securing a loan
again so that an individual can use their car in a bank or credit union to
secure a lower interest rate on the loan and not necessarily be involved in a
circumstances of the vehicle title and finally we made sure that Lee societies
continue to use of violence to secure the loans to pay provide to service
members obviously to continued access to beneficial small-dollar loans the primary requirement if you recall
the laws that we describe disclosures provided in Truth in Lending Act our
continued that’s basically the default setting of
the partial credit industries to use its closures have quite truth winning act it
does require the nati are to be disclosed as part of the law but because
the Truth in Lending Act already puts out an APR that is prominent in a box
that defines the interest cost to the consumer we felt the department felt that it was
continuing to provide different percentage along with that that might
reflect as the matr and because the No attending actors associated more with
the restrictions and limitations there provided not necessarily disclosures at
retail lending activity screw disclosure regime the department’s elected to have
Orlowski creditors to just described the MapR what would be what is included in
the MapR and what the limitation provided by the military lending it
provides them in terms of the MapR rather than disclosing it calculated and
out allows creditors to covers D issue of
mandatory arbitration in their contracts by disclosing that mandatory arbitration
you would not impact a third borrowers like it does a regular consumer and
finally to allow online lenders credit card companies store credit providers
who are using a national credit card to provide their store credit we’ve we’ve
allowed for the defense allowed creditors to use all disclosures through
a toll free number so that the predator just needs to provide that
toll-free number and the borrower can then access that number to get the or
disclosures d changed the way the creditors to fulfill
their compliance requirements to the degree that and all explain it but it’s
always been that the creditor can either offer the credit that complies with the
rule or to satisfy their compliance needs date they need to identify the
covered bar to ensure they don’t provide a loan that doesn’t fit within the
military landing AK restrictions to a covered borrower the difference now
instead the borrowers no longer required to self-identify orphan status to the
creditor as it had been in a previous creditors now going to be granted the
safe harbor if they use a defense manpower data center database or one of
the credit reporting agency to determine if the covered borrower arista borrower
is is part of coverage group the creditor could also use it their own system to verify whether a
client is a covered baller all those debt just not provide them safe harbor
in terms of ensuring client important issue right now it’s the
effective in compliance states it was published as I said on the 21st of July
it goes into effect on the 1st of October of this year but creditors are
not required to comply with it until October 2016 if they provide other than
credit cards and then for credit card credit card providers they have until
October 2017 this is to provide ample opportunity to create systems necessary
to provide service members credit that fills the requirements to the notary
Lending Act and not limit the options that are available to service members those too suki consumer 6 you may want to pass on to
them Lending Act doesn’t cover all predatory
lending as part of her talked about there’s opportunities for lending
although they don’t know the providers of the services do not consider
themselves to be lenders to rent to own true certainly mortgages or through
purchase loans there’s an opportunity to still creating an environment where the
individual is taking advantage then a joke because of the vulnerability to the
enolate covers considerably more than it used to but it doesn’t cover every its incumbent upon the creditor now to
identify the covered borrower whereas before the Dobara where would be asked
are you remember the military and it was an opportunity for some level of
collusion with the creditor or perception on the part of the borrower
to go ahead and get this high cost long now D the rule requires that the the creditor
do the identification without any support from the ball another aspect to
it emphasizes that the military Lending Act is about restrictions and it’s not
about disclosures and that’s one of the key aspects and being tried to the Truth
in Lending Act the truth and the ex still provides all the the critical disclosures for the
consumer the military landing at my age restrictions and limitations to protect
our military consumers only limit good credit options there’s lots
of opportunities for service members and their families to get credit below 36 percent APR as you’re well
aware and the restrictions set of provided perhaps a 88 points for D military consumer to recognize that if
they cannot get it correct alone for less than 36 percent That’s
Navy the time to consider other options for getting 88 cash and some assistance
with their overall long-term credit asked outlook so we we felt very
strongly that as barber all spoke he said in her presentation people can
borrow their way out of debt and we’re hoping that this is a a another way of
protecting service members so that they can responsibly use credit they can
continue to have a good relationship with their finances and have a long-term
positive outlook for their financial well-being I can attack to our moderator thank you it was a great presentation one had any
questions for presenters please put them in the chat and will address those in
the remaining we have we have here the contact information for dr. Barbara
O’Neil and Marcus but we’re card I will share their email addresses in the chat question about hard money lender what
are you referring to this is a question that was born a chaplain earlier
barbara’s after the presentation person that asked that could give a little more
detail but would be happy to respond to your question you know I’m kinda figured hard money
I’m thinking is this something to do with primer who exactly are we talking
about here and see their Christian btw know you’re asking I did answer to that
question though about the the rent-to-own for housing I could never
really talking mostly about consumer items and certainly people can rent to
own house for example and a big issue of courses is how long you gonna be in an
area which is people have a good relationship between the owner of the
house and they’re renting it like it at some point nothing wrong with that I’ve
seen many people get into housing but that way but you just really have to
have a good relationship and as a within the answer it’s really important to get
a contractor 100 just like he would have for any old contract I need to specify
the duration of the contract amount of money that’s in question that has to the
who’s responsible for that you need to work with an experienced real estate
attorney to really 2010 question here on the military Lending
Act one is the industry compliance by day court dates again on our October on third 2016 for all lenders outside of
credit cards and then credit cards its October 3rd of 2017 for those who would like to actually see
the new it’s available on the Federal Register if you go to the Federal
Register side and in their search box type the end 32 CFR Part 2 32 that’s the
number for admin for the role it should ring 6 documents to the to the military Lending Act and
choose the one that’s dated 22 July because 15 to provide you a PDF copy from that
website I just answered that mark me from what I can see in the definition
seems like there sorry rain what was being said I’m going the mission of the where to find the Federal
Register notice great if anyone has any further
questions please feel free to put this in the chapter will address and we can I
will go ahead in before it ships live with the evaluation and post-test link
this link will take you to US population with the webinar completion of which you
will get her be given another link to the extension past that with 80% higher
and receive your certificate of completion an email and I’ll put that
link and the chap hot here what are as a group or one and a half
see you or AFC’s and CPSC September 15th with dr. Daniel and Mary
bensinger on estate planning basics and advanced directives you can register for
that event and learned extension outdoor / events / 2149 the question here about
the chat pot shots input you can go back and watch the wording of this
presentation and that will include all of the chatbox interaction question the
recording will be available here and there is another today the Department of Defense office
the reintegration programs in partnership with the Army Community
Service did invite you to join us in our in a professional development series
today at 2:00 p.m. Eastern learn what makes a strong healthy family be sure to
RSVP and I will put that are sleeping over to be see you slide in case anyone
has any questions about that will turn would like to thank you all just wanted to say to you thank you
choose barber shirt and a woman’s personal its constitution and she burst
into a grandpa be pretty associate bringing russians colectomy
anyone interested in learning more about this is that you gotta find all we also
not just personal and it’s not just us thank you so many questions if you think of
something and following today’s the heart

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