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The Department of Defense (DoD) has issued a report to the House Committee on Armed Services regarding the impact of a Military Annual Percentage Rate (MAPR) cap lower than 30% on military readiness and servicemember retention.  The DoD, in consultation with the Treasury Department, was required to provide the report by the National Defense Authorization…

On July 1, Virginia Governor Northam signed Senate Bill 1410 which amended several Virginia anti-discrimination statutes to prohibit discrimination based on “military status.”  For purposes of the various amendments, the term “military status” is defined as:

status as (i) an active military service member who performs full-time duty in the Armed Forces of the United…

In another action demonstrating that a “new CFPB” is in place under the Biden Administration, the CFPB has issued an interpretive rule setting forth the basis for its determination that it has authority to examine institutions that it supervises for Military Loan Act (MLA) compliance.

In 2018, under the leadership of former Acting Director Mulvaney,…

On May 6, 2021, the CFPB’s Office of Servicemember Affairs issued its eighth annual report summarizing its activities from January 1 through December 31, 2020.  The report discussed the Office’s consumer outreach and educational efforts, servicemember complaint trends, and priorities for 2021.

The Office’s educational outreach focused on specific economic challenges and resources related to…

Consumer advocates often contend that Congress should prohibit arbitration agreements with class action waivers because servicemembers and other consumers need class actions to effectuate their statutory rights.  However, a report issued by the Government Accountability Office (GAO) to Congress last month contains data that refutes that argument.

The GAO report studied the impact of mandatory…

In a blog post published on January 28, 2021 sharing a statement sent to CFPB staff, Acting Director David Uejio announced several new priorities for the CFPB’s Supervision, Enforcement and Fair Lending Division under the Biden Administration.  In addition to prioritizing COVID-19 relief and racial equity, the CFPB will take new aim at Military Lending…

On December 30, 2020, the CFPB announced a consent order with Omni Financial of Nevada, Inc. based on alleged violations of the Military Lending Act (MLA) and Electronic Funds Transfer Act (EFTA).  This is the second consent order announced as part of a sweep of investigations for potential MLA violations.

According to the CFPB, Omni…

The Federal Trade Commission (FTC) has launched a new online “dashboard” that makes certain data received from active duty servicemembers and veterans publicly available. The data come from the FTC’s Consumer Sentinel Network, which aggregates consumer complaints received directly from consumers, as well as data contributions received from others (including state attorneys general, the CFPB,…

Earlier this month, the Office of Servicemember Affairs (OSA) released its annual report covering the Office’s activities during fiscal year 2019, which covers the period of October 1, 2018 to September 30, 2019.

Noteworthy items include:

  • Top Complaints Received from Military Consumers During FY19.  In FY19, the same overall number of complaints (34,600) were submitted

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In a new interpretive rule published on February 28, 2020, the Department of Defense (DoD) has announced that it is withdrawing guidance previously issued in its December 14, 2017 Interpretive Rule, Q&A #2, governing motor vehicle and other personal property financing, and will revert back to the position it set forth in the original…