Additional MLA Guidance

The Department of Defense has published an amendment to its interpretive Q&A on the Military Lending Act regulation, “Limitations on Terms of Consumer Credit Extended to Service Members and Dependents.”  On August 26, 2016, the Department issued the first set of interpretations of that regulation in the form of questions and answers; this interpretive rule amends and adds to those questions … Read More

MLA Website Error

According to an announcement posted on the Military Lending Act (“MLA”) Website: Between 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 … Read More

NCUA Letter to Credit Unions 16-CU-07 Military Lending Act Examination

Starting October 3, 2016, credit unions must comply with the amended regulation the Department of Defense issued implementing the Military Lending Act. With this amended rule, NCUA intends to take the same examination approach used with the Consumer Financial Protection Bureau’s TILA-RESPA Integrated Disclosures rule in 2015 and its Qualified Mortgage and Ability-to-Repay rules in 2014. NCUA examiners are instructed … Read More

MLA Interpretive Rule

The Department of Defense released its anticipated Guidance in regards to the new Military Lending Act requirements, effective October 3, 2016.  The Guidance is in the form of questions and answers, which are replicated below.  The Guidance is an Interpretive Rule, and will be published in the Federal Register and effective August 26, 2016. While the questions do address whether the … Read More

Complying with Recent Changes to the Military Lending Act

NCUA released Regulatory Alert 16-RA-04 providing guidance on complying with the changes to the Military Lending Act requirements. The guidance, Complying with Recent Changes to the Military Lending Act Regulation, provides a good overview of the changes, and the steps that the credit union will have to take. Along with an overview of the changes, the guidance includes how to … Read More

Military Lending Act Covered Borrower Database Access

If the credit union wishes to use the DMDC (Defense Manpower Data Center) direct connection capability (under development) to identify borrowers covered under the MLA (Military Lending Act) should email a request to the DMDC at dodhra.dodc-mb.dmdc.mbx.mla@mail.mil, by February 1. The MLA places certain protections over covered borrowers, including a cap on annual percentage rates, so credit unions need to … Read More

Military Lending Act… continued

We blogged about the new requirements for the Military Lending Act (MLA) previously.  In summary, the final rule broadens the MLA protections by expanding the range of covered loans, defining a covered borrower, adding more components to the MAPR, placing restrictions on imposing other limitations, and requiring a statement of the MAPR Disclosure.  Compliance with the changes is required by … Read More