The Department of Defense (DoD) dramatically expanded the scope of the Military Lending Act (MLA) on July 22, 2015, publishing its Final Rule amending the MLA’s implementing regulation. The DoD consulted with the CFPB in developing the Final Rule, and the CFPB actively supported the DoD’s plans to expand MLA coverage.
MLA coverage was previously limited to only three types of consumer credit extended to active-duty service members and their dependents: closed-end payday loans with a term of 91 days or less in which the amount financed does not exceed $2,000, closed-end vehicle title loans with a term of 181 days or less, and closed-end tax refund anticipation loans. The Final Rule extends the MLA’s 36 percent interest cap and other restrictions to a host of additional products, including credit cards, installment loans, private student loans and federal student loans not made under Title IV of the Higher Education Act, and all types of deposit advance, refund anticipation, vehicle title, and payday loans (residential mortgages and purchase-money personal property loans are excluded). Although the Final Rule takes effect on October 1, 2015, it will apply only to consumer credit transactions or accounts that are consummated or established after October 3, 2016 for most products, and after October 3, 2017 for credit cards.
On August 24, 2015, Ballard Spahr attorneys will hold a webinar on the Final Rule from 12 p.m. to 1 p.m. ET. The webinar registration form is available here.
For more on the Final Rule, see our legal alert.