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Disclosure of MAPR in Conjunction With Covered Borrower ID Statement

Question: 
Is the MAPR required to be disclosed any time our bank also uses the Covered Borrower ID Statement or only if the loan is a covered loan (closed-end secured by a titled motor vehicle with a term less than 181 days for a purpose other than a purchase)? We are a very rate-friendly lender already and don't want to take a chance on holding ourselves to a yet lower rate if we refinance the loan later on. Under the Talent Amendment, we aren't sure.
Answer: 

The MAPR is required if the transaction is truly a covered loan. If your bank obtained a Covered Borrower ID Statement from the borrower, it is not required to disclose the MAPR if the transaction is not a covered transaction. The Covered Borrower ID Statement provides the documentation to support whether the transaction is or is not a covered transaction.

Vendor: 
Wipfli

First published on 09/07/2015

Filed under: 
Compliance
Filed under compliance as: 
APR/APY

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