Mon, May 8, 2017
The MLA requires a statement of the MAPR and a clear description of the covered borrower's payment obligation to be provided to the covered borrower orally. Creditors may satisfy this requirement by providing the information to the covered borrower in person at a face-to-face meeting or through a toll-free telephone number. The toll-free number must be provided on the loan application used to apply for the loan or on a written disclosure provided by the creditor to the covered borrower.
The DoD's Official Interpretation states that the required disclosures must be available from the time the creditor provides the toll-free number. For example, if the toll-free telephone number is provided on the loan application, the disclosures provided through the toll-free number must be available from the time the application is provided to the covered borrower. The Interpretations also state that the oral disclosures provided through the toll-free number must only be available for a time period reasonably necessary to allow a covered borrower to contact the creditor in order to listen to the disclosures.
However, if the oral disclosures are the same for every covered borrower, there would be no need to limit their availability for any particular time period.