Early last year, several trade groups, including the National Automotive Dealers Association (NADA), sent letters petitioning the Department of Defense (DoD) to rescind or withdraw Question and Answer #2 (Q&A 2) from its 2016 interpretative rule for the Military Lending Act (MLA) final rule and its December 2017 amendments. Q&A 2 has generated much uncertainty
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CFPB seeking legislative fix to give it clear MLA examination authority
By John L. Culhane, Jr. & Anthony C. Kaye on
The CFPB announced yesterday that it has transmitted a proposal to Congress that would give it clear authority to conduct supervisory examinations for compliance with the Military Lending Act (MLA).
Last summer, former CFPB Acting Director Mulvaney reportedly announced that he planned to end routine examinations for MLA compliance because the Dodd-Frank Act did not…
Democratic Senators Urge Mulvaney to Reconsider MLA Supervision Policy Change
By Jeremy C. Sairsingh on
In response to reports that Acting CFPB Director Mick Mulvaney intends to dispense with routine supervisory examinations of creditors for violations of the Military Lending Act (MLA), Senate Democrats sent a joint letter addressed to Mulvaney in his capacity as Director of the Office of Management and Budget—urging him to reconsider.
The letter, signed by…
Military Lending Improvement Act of 2018 introduced in the U.S. Senate
By Anthony C. Kaye on
On August 1, 2018, Sen. Bill Nelson (D-Florida) introduced S. 3334 captioned “The Military Lending Improvement Act of 2018” in the United States Senate to “expand and improve” credit protections afforded to service members by the Military Lending Act (MLA) and the Fair Debt Collection Practices Act (FDCPA). If this bill becomes law, it…
Trade groups ask Defense Dept. to rescind MLA interpretation on GAP insurance financing
By John L. Culhane, Jr. on
Posted in Federal CFS Monitor, Military Issues
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 …
DoD issues MLA interpretive rule; Ballard to hold Sept. 20 webinar
By Anthony C. Kaye on
Posted in Military Issues
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…
Defense Department dramatically expands scope of Military Lending Act
By Barbara S. Mishkin on
Posted in Military Issues
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.
MLA coverage was previously…