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The Department of Defense announced in its Fall 2019 rulemaking agenda that it is engaged in proposed rulemaking to amend its Military Lending Act (MLA) regulations, apparently in order to allow non-bank creditors to provide secured auto financing for purchase transactions.  (The DoD’s agenda was filed as part of the Fall 2019 Unified Agenda of…

In its recently published Summer 2019 Newsletter, the Washington State Department of Financial Institutions (“DFI”) reported that it had interpreted the Servicemembers Civil Relief Act (“SCRA”) broadly to apply the SCRA’s 6% interest rate cap to a loan agreement entered into only by a servicemember’s spouse.  Generally, the SCRA provides for a 6% interest…

On August 21, 2019, President Trump signed a Presidential Memorandum that streamlines the process by which totally and permanently disabled veterans can discharge their Federal student loans (Federal Family Education Loan Program loans, William D. Ford Federal Direct Loan Program loans, and Federal Perkins Loans).  Through the revamped process, veterans will be able to have…

On June 27 the Senate passed the Gold Star Spouses and Spouses of Injured Servicemembers Leasing Relief Expansion Act as part of the Fiscal Year 2020 National Defense Authorization Act (see Sec. 6007). If it becomes law, the bill would amend the SCRA to allow spouses of servicemembers killed or injured during service to terminate…

The FTC has issued a final rule to implement a 2018 amendment to the FCRA made by the Economic Growth, Regulatory Relief, and Consumer Protection Act that requires nationwide consumer reporting agencies  (CRAs) to provide free electronic credit monitoring service for active duty military consumers.  The rule will be effective 30 days after its publication…

A Federal Register entry published last week details a proposed data-sharing arrangement between the Department of Defense (DoD) and the Department of Education (DoE) designed to reduce the amount of interest that certain active duty service members pay on federal student loans.

In 2008, Congress amended the Higher Education Act to provide for the removal…

The Justice Department announced in a March 15 press release that it has reached an agreement with property management company PRG Real Estate Management (PRG) and several related entities to settle claims that PRG violated the Servicemembers Civil Relief Act (SCRA) by obtaining evictions and money judgments against service-member tenants by filing affidavits that did…

The CFPB recently published the latest complaint snapshot report which detailed complaint numbers, trends, and top issues reported by servicemembers, veterans, and their families across the country. The report provides complaint information nationwide and on a state-by-state basis for all 50 states and the District of Columbia. It covers complaints submitted throughout 2018 and notes…

On March 6, 2019, a California subprime auto lender, California Auto Finance, agreed to enter into a consent order with the Justice Department related to allegations that it repossessed vehicles in violation of the Servicemembers Civil Relief Act (SCRA). Under the terms of the consent order, which is still subject to court approval, California…

Early last year, several trade groups, including the National Automotive Dealers Association (NADA), sent letters petitioning the Department of Defense (DoD) to rescind or withdraw Question and Answer #2 (Q&A 2) from its 2016 interpretative rule for the Military Lending Act (MLA) final rule and its December 2017 amendments.  Q&A 2 has generated much uncertainty…