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 Rule’s October 3, 2016 compliance deadline for most products other than credit cards.… Continue Reading
military lending act
MLA compliance deadline for credit card accounts is Tuesday, October 3
The Military Lending Act (MLA) will apply to credit card accounts starting Tuesday, October 3. The final rule took effect last October but provided a one-year exemption for “credit extended in a credit card account under an open-end (not home-secured) consumer credit plan.” Although the final rule permits the Secretary of Defense to extend the exemption for up to one year (October 3, 2018), the DoD declined to do so and is allowing the exemption to expire next week.… Continue Reading
MLA Website malfunction
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 Record Request file that failed to process submit the file again for processing.… Continue Reading
FDIC Releases Revised MLA Exam Procedures and Sets Supervisory Expectations
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
CFPB and FFIEC Release Updated MLA Exam Procedures; NCUA Will Accept Reasonable and Good Faith Efforts to Comply
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
DoD issues MLA interpretive rule; Ballard to hold Sept. 20 webinar
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
Trade groups seek de facto extension of compliance date for Military Lending Act final rule
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
Trade groups seek clarifications to Military Lending Act regulations
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