In addition to amendments to the Fair Credit Reporting Act dealing with the reporting of adverse information on servicemembers by consumer reporting agencies, the National Defense Authorization Act (NDAA) as passed by the...more
The Department of Defense (DoD) has issued a report to the House Committee on Armed Services regarding the impact of a Military Annual Percentage Rate (MAPR) cap lower than 30% on military readiness and servicemember...more
In another action demonstrating that a “new CFPB” is in place under the Biden Administration, the CFPB has issued an interpretive rule setting forth the basis for its determination that it has authority to examine...more
On December 30, 2020, the CFPB announced a consent order with Omni Financial of Nevada, Inc. based on alleged violations of the Military Lending Act (MLA) and Electronic Funds Transfer Act (EFTA). This is the second consent...more
In a new interpretive rule published on February 28, 2020, the Department of Defense (DoD) has announced that it is withdrawing guidance previously issued in its December 14, 2017 Interpretive Rule, Q&A #2, governing motor...more
3/2/2020
/ Consumer Financial Products ,
Consumer Financial Protection Bureau (CFPB) ,
Consumer Insurance Products ,
Consumer Lenders ,
Department of Defense (DOD) ,
Financial Transactions ,
Financing ,
Interpretive Rule ,
ITIN ,
Military Lending Act ,
Military Service Members ,
Motor Vehicles ,
Personal Property ,
Regulatory Requirements ,
Residency Status ,
Safe Harbors
The Department of Defense announced in its Fall 2019 rulemaking agenda that it is engaged in proposed rulemaking to amend its Military Lending Act (MLA) regulations, apparently in order to allow non-bank creditors to provide...more
12/5/2019
/ Amended Regulation ,
Automotive Industry ,
Automotive Loans ,
Borrowers ,
Consumer Lenders ,
Creditors ,
Department of Defense (DOD) ,
Fair Access to Credit ,
Financial Regulatory Reform ,
Financial Services Industry ,
Financing ,
Lenders ,
Military Lending Act ,
Military Service Members ,
Motor Vehicles ,
Non-Bank Lenders ,
Regulatory Agenda ,
Regulatory Burden ,
Rulemaking Process
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)....more
Twenty-three Democratic members of the House Financial Services Committee have sent a letter to Kathy Kraninger, the CFPB’s new Director, urging the Bureau to resume examining its supervised entities for compliance with the...more
12/17/2018
/ Banking Examinations ,
Consumer Financial Products ,
Consumer Financial Protection Bureau (CFPB) ,
Consumer Lenders ,
Failure to Comply ,
Financial Services Industry ,
Military Lending Act ,
Military Service Members ,
Regulatory Agenda ,
Regulatory Oversight ,
Regulatory Standards
On August 10, the New York Times reported that Mick Mulvaney, the CFPB Acting Director, intends to dispense with routine supervisory examinations of creditors for violations of the Military Lending Act (MLA). ...more
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...more
The Department of Defense (DoD) is reported to have rejected the request of the National Association of Federally-Insured Credit Unions (NAFCU) to extend the October 3, 2017 date for credit card compliance with the Military...more
We recently reported on a bill introduced in the House of Representatives by Congressman Dan Kildee (D-Michigan) that would amend the Military Lending Act (“MLA”) to require that creditors provide additional disclosures to...more
On May 25, Congressman Dan Kildee (D-Michigan) referred a bill to the House Committee on Armed Services titled the “Transparency in Military Lending Act of 2017.” ...more
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...more
9/9/2016
/ American Bankers Association ,
Banking Sector ,
Consumer Financial Products ,
Consumer Financial Protection Bureau (CFPB) ,
Consumer Lenders ,
Department of Defense (DOD) ,
EFTA ,
FDIC ,
Federal Reserve ,
Industry Examinations ,
Interpretive Rule ,
Military Annual Percentage Rates (MAPR) ,
Military Lending Act ,
Military Service Members ,
OCC ,
Regulation E ,
Safe Harbors ,
Truth in Lending Act (TILA)
The American Bankers Association, joined by six other prominent industry trade groups, is seeking a six-month extension of the date by which depository institutions must comply with the Military Lending Act (MLA) final rule...more
9/2/2016
/ Banking Sector ,
Consumer Financial Products ,
Consumer Financial Protection Bureau (CFPB) ,
Department of Defense (DOD) ,
Depository Institutions ,
FDIC ,
Federal Reserve ,
Financial Institutions ,
Military Lending Act ,
Military Service Members ,
NCUA ,
OCC ,
Time Extensions
According to Politico, Holly Petraeus, Assistant Director of the CFPB’s Office of Servicemember Affairs, will be retiring from the CFPB. During her tenure at the CFPB, the protection of military servicemembers and their...more
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...more
The Department of Defense has extended the deadline for requesting direct access to its Military Loan Act (MLA) Defense Manpower Data Center (DMDC) database until February 15, 2016. Under amendments to the MLA's implementing...more
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. MLA coverage was previously limited to...more
7/28/2015
/ Automotive Loans ,
Consumer Financial Protection Bureau (CFPB) ,
Consumer Lenders ,
Credit Unions ,
Department of Defense (DOD) ,
Financial Services Authority ,
Higher Education Act ,
Lenders ,
Military Lending Act ,
Military Service Members ,
Payday Loans ,
Regulation Z ,
Title IV
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...more
The Department of Defense's (DoD) proposed rule to revise and expand the coverage of its rule implementing the Military Lending Act (MLA) may be put on hold. The House Committee on Armed Services Subcommittee for Military...more
The Department of Defense (DoD) has issued a proposal to revise and significantly expand the coverage of its rule implementing the Military Lending Act (MLA). The proposed revisions would limit interest charged to...more