Compliance: CUNA updates MLA card fee spreadsheet
CUNA has updated its Military Lending Act (MLA) credit card fee comparison spreadsheet for the third quarter, updated as of September 2018. The updated resource can be found in the CUNA Compliance Community’s “Compliance Resources” tab, and under the “Resources” tab in CUNA’s MLA e-Guide.
This update is necessary because, 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 that 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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