Can anyone verify that I am understanding this correctly:

(1) The credit card provisions apply only to new credit cards issued after 10.3.17. At that time, we'll run the database check on all new apps (and re-issues if applicable at or after this date as well).

(2) As far as monitoring for MAPR violations, again, this will only apply to credit cards opened after 10.3.17 for Military individuals we've identified through the database check. If the MAPR is over the limit, we need to refund fees to get below the 36% threshold.

Thanks for the help!

That is correct.

Just make sure that in (2) you are monitoring the MAPR on a monthly basis to ensure the MAPR does not exceed 36% in a given statement cycle.

There are disclosure requirements that are part of MLA as well, and providing a 1-800. Or am I off-base..no pun intended.

Well yes, there are other requirements, like the disclosures as you suggested. The OP was just asking if their two points were correct though.

For our existing portfolio before October effective date - going forward if we offer a limit increase to existing credit card holders, do we need to run them through the MLA tests?

Only guidance that kind of touches is regarding the covered member test at the time of becoming obligated. If the obligation is increasing (due to our limit increase offer) does that fall under the need to test for status? Then does it become a credit card that is required to be tested for MLA APR too?

Any help is appreciated.

It probably depends on how the increase is done.

For us, we will do a new application for an increase. So we will check MLA at that time.

However, we also do a "portfolio review" and will increase (or potentially decrease) the limit if they meet certain qualifications. At that time we would not check MLA.

Is this the "right" way? I have no idea, but this is how we are moving forward until told otherwise. But I am curious to see what others are doing as well.

CULady, we do the same as you and do a new application for an increase. We will check MLA status at that time. My question is at what point do you provide the member with the MLA statement in this process?

We will hand out new disclosures with the increase, so prior to funding they would get the MLA information.