On October 17, the FDIC released revised interagency Military Lending Act (MLA) examination procedures for use in connection with consumer credit transactions occurring on or after October 3, 2016. The revised procedures reflect the Department of Defense’s July 2015 final rule and August 2016 interpretive rule and appear consistent with those released by the CFPB and FFIEC last month.… Continue Reading

On September 30, the CFPB released updated examination procedures for Military Lending Act (MLA) compliance. Compliance with the final rule amending the MLA, issued by the Department of Defense (DoD) in July 2015, was required for creditors of most consumer credit products as of this past Monday, October 3. The final rule applies to all consumer credit transactions or accounts for consumer credit “consummated or established” on or after October 3, 2016.… Continue Reading

The Department of Defense (DoD) has issued an interpretive rule to assist the industry in complying with its July 2015 final rule amending the Military Lending Act’s implementing regulation.  The much-anticipated guidance was published in the Federal Register on August 26, 2016, just over one month before the final rule’s October 3 compliance deadline for most products other than credit cards.… Continue Reading

The American Bankers Association, joined by six other prominent industry trade groups, is seeking to postpone by six months the date on which examiners will begin transactional testing of depository institutions for compliance with the Military Lending Act (MLA) final rule adopted by the Department of Defense (DoD) in July 2015 that dramatically expanded the scope of the MLA’s coverage. … Continue Reading

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 DoD’s plans to expand MLA coverage.… Continue Reading