What is the Military Annual Percentage Rate (MAPR) in Illinois? Is it greater than 36% for covered transactions?

Illinois does not have a “military annual percentage rate” (MAPR), because that term is specific to “consumer credit” loans covered under the federal Military Lending Act (MLA).

The MAPR is a broad term used in federal MLA regulations to refer to the total cost of “consumer credit.” The MAPR applies to all loans incurred by service members while on active duty that are made for personal, family or household purposes and are subject to a finance charge or payable by a written agreement in more than four installments (with the exception of residential mortgage loans and purchase-money loans, which are covered by the federal Servicemembers Civil Relief Act).

Illinois’ military lending law — titled the Illinois Servicemembers Civil Relief Act — does not use the term MAPR. Instead, the Illinois law limits “finance charges” on loans to active duty service members that were made before they entered military service — to “6% per annum.”

For resources related to our guidance, please see:

  • Military Lending Act Regulations, 32 CFR 232.3(p) (“The MAPR is the cost of the consumer credit expressed as an annual rate, and shall be calculated in accordance with § 232.4(c).”)

  • Military Lending Act Regulations, 32 CFR 232.3(f) (“Consumer credit means credit offered or extended to a covered borrower primarily for personal, family, or household purposes, and that is: (i) Subject to a finance charge; or (ii) Payable by a written agreement in more than four installments.”)

  • Military Lending Act, 10 USC 987 (“The term “consumer credit” has the meaning provided for such term in regulations prescribed under this section, except that such term does not include (A) a residential mortgage, or (B) a loan procured in the course of purchasing a car or other personal property, when that loan is offered for the express purpose of financing the purchase and is secured by the car or personal property procured.”)

  • Illinois Service Member Civil Relief Act, 330 ILCS 63/40 (“Interest or finance charges collected or charged to a service member who has entered military service, or the spouse of that service member, in connection with an obligation entered into on or after the date of August 22, 2005, but prior to the date that the service member entered military service, shall be subject to Section 4.05 of the Interest Act.”)

  • Illinois Interest Act, 815 ILCS 205/4.05 (“Notwithstanding any contrary provision of State law, but subject to the federal Servicemembers Civil Relief Act, no creditor in connection with an obligation entered into on or after the effective date of this amendatory Act of the 94th General Assembly, but prior to a service member's period of military service, shall charge or collect from a service member who has entered military service, or the spouse of that service member, interest or finance charges exceeding 6% per annum during the period of military service.”)