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Four trade groups have sent letters to the Department of Defense (DoD) asking the DoD to rescind or withdraw Question and Answer #2 (Q&A 2) from its 2016 interpretative rule for the Military Lending Act final rule (MLA Rule) and its December 2017 amendments to the interpretive rule.  One letter was sent by the National Association of Federally-Insured Credit Unions (NAFCU) and the Defense Credit Union Council (DCUC) and another was sent by the Credit Union National Association (CUNA) and the DCUC.… Continue Reading

The CFPB has issued a new “snapshot of servicemember complaints.”  The report states that as of November 2015, the CFPB had received about 2,500 complaints from servicemembers, veterans and their dependents about high-cost consumer credit.  These complaints were submitted under two complaint categories: the “payday loan” category or under the “debt collection” category with “payday loan” indicated as the sub-product. … Continue Reading

The Department of Defense (DoD) dramatically expanded the scope of the Military Lending Act (MLA) on July 22, 2015, publishing its Final Rule amending the MLA’s implementing regulation.  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

Yesterday, the House Armed Services Committee removed language from the draft Fiscal Year 2016 National Defense Authorization Act that would have delayed the finalization of rules proposed by the Department of Defense that would expand the types of credit subject to the Military Lending Act.  As we have previously discussed, the proposal faces strong criticism from the financial services industry.… Continue Reading

Despite the CFPB’s efforts to build support for the Department of Defense’s proposal to significantly expand Military Loan Act coverage, it now appears that the proposal may be put on hold.

The DoD proposal would revise the scope of “consumer credit” subject to MLA restrictions to include, regardless of term or amount, all unsecured open-end lines of credit, credit cards, payday loans, vehicle title loans, refund anticipation loans, deposit advance loans, and installment loans. … Continue Reading

In an effort to build support for the Department of Defense’s proposal to significantly expand Military Loan Act coverage, the CFPB has released a report entitled “The extension of high-cost credit to servicemembers and their families.”  The DoD proposal would revise the scope of “consumer credit” subject to MLA restrictions to include, regardless of term or amount, all payday loans, vehicle title loans, refund anticipation loans, deposit advance loans, installment loans, unsecured open-end lines of credit, and credit cards.… Continue Reading

The American Bankers Association, Consumer Bankers Association, Independent Community Bankers of America, National Association of Federal Credit Unions, and Association of Military Banks of America have submitted a 59-page letter commenting on the Department of Defense’s proposed revisions to its Military Loan Act regulations.

The proposal, which was issued in September to implement MLA amendments made by the 2013 Defense Authorization Bill, would significantly expand MLA coverage to include all payday loans, vehicle title loans, refund anticipation loans, deposit advance loans, installment loans, unsecured open-end lines of credit, and credit cards. … Continue Reading

As anticipated, the Department of Defense’s proposed regulations to implement provisions of the Military Loan Act added by the 2013 Defense Authorization Bill would significantly expand MLA coverage.  The proposed revisions would limit interest charged to servicemembers and their dependents on all payday loans, vehicle title loans, refund anticipation loans, deposit advance loans, installment loans, unsecured open-end lines of credit, and credit cards and require creditors to screen all applicants against a DoD database before offering such products with rates greater than 36 percent. … Continue Reading

While Director Cordray’s appearance at the House Financial Services Committee’s hearing on the CFPB’s fifth Semi-Annual Report yesterday was accompanied by the usual dose of political theater, his testimony did yield the following items of noteworthy information: 

  • The CFPB will be issuing a white paper later this summer regarding use of the proxy methodology for identifying discrimination in indirect auto financing. 
… Continue Reading