department of defense

Department of Defense Reverts to Prior Position on MLA Interpretive Rule Q&A #2 Regarding Motor Vehicle and Personal Property Financing and Issues New Guidance on the Use of ITINs in Verifying MLA Covered Borrower Status; Ballard Spahr to hold webinar on March 13

By Rachel R. Mentz & Ballard CFS Group on March 2, 2020

Posted in Military Issues, Regulatory and Enforcement

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…

Department of Defense Proposes Data Sharing Arrangement with Department of Education to Identify Service Members Eligible for 0% Interest on Federal Student Loans

By Ballard CFS Group on April 23, 2019

Posted in Dept. of Education, Military Issues, Regulatory and Enforcement

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…

Trump Administration Plans to End Military Lending Act Prohibition on Offering GAP Insurance to Service Members in Auto Loan Transactions

By Rachel R. Mentz on August 21, 2018

Posted in Federal Agencies, Military Issues, Regulatory and Enforcement, Vehicle Loans

NPR reported last week that the Trump Administration is planning to end the current prohibition under the Military Lending Act (“MLA”) against creditors offering service members GAP insurance in connection with credit intended to finance the purchase of motor vehicles. Current interpretive guidance concerning the Department of Defense’s regulations implementing the MLA prohibits creditors from…

Department of Defense Issues Additional MLA Rule Interpretive Guidance; SCRA Foreclosure Protections Extended

By Ballard CFS Group on December 18, 2017

Posted in Federal Agencies, Military Issues, Regulatory and Enforcement

Last week the Department of Defense (DoD) issued an interpretive rule under the DoD’s Military Lending Act final rule (MLA Rule). The interpretive rule amends four of the “Q&A” format interpretations that DoD issued on August 26, 2016. Readers may recall that the DoD published this guidance just over one month before the MLA…

MLA Website malfunction

By Juliana D. Gerrick on February 21, 2017

Posted in Military Issues, Regulatory and Enforcement

According to an announcement posted on the Military Lending Act (“MLA”) Website,
“[b]etween February 9, 2017 and February 15, 2017 there was a problem with MLA Multiple Record Requests that prevented 149 request files from processing.” The Defense Manpower Data Center advises any creditor who, during the time period in question, submitted a Multiple…

Trade groups seek clarifications to Military Lending Act regulations

By Ballard CFS Group on April 11, 2016

Posted in Military Issues, Regulatory and Enforcement

A number of prominent industry trade groups have written to the Department of Defense (DoD) seeking clarifications to the Military Lending Act (MLA) final rule adopted in July 2015 that dramatically expanded the scope of the MLA’s coverage. The DoD consulted with the CFPB in developing the final rule, and the CFPB actively supported the…