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 National Defense Authorization Act as passed by the House and now headed to the Senate includes amendments to the Fair Credit Reporting Act dealing with the reporting of adverse information on servicemembers by consumer...more
On July 1, Virginia Governor Northam signed Senate Bill 1410 which amended several Virginia anti-discrimination statutes to prohibit discrimination based on “military status.” For purposes of the various amendments, the term...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
Earlier this month, the Office of Servicemember Affairs (OSA) released its annual report covering the Office’s activities during fiscal year 2019, which covers the period of October 1, 2018 to September 30, 2019....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 has issued a report, “Mortgages to First-time Homebuying Servicemembers,” that focuses on mortgage loans made from 2006 to 2016 to first-time homebuyers who are serving in the military or are veterans....more
The CFPB’s Office of Servicemember Affairs has released its annual report on complaints submitted to the Bureau by servicemembers....more
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 Washington state Senate and House of Representatives have passed a bill (House Bill 1056) that would expand the coverage of the Washington Service Members’ Civil Relief Act (WSCRA) and provide additional protections to...more
The CFPB’s October 2017 complaint report, which the CFPB calls a “special edition” monthly complaint report, departs from the format of the CFPB’s standard monthly reports. (The CFPB’s June and July 2017 complaint reports...more
11/2/2017
/ Bank Accounts ,
Banking Sector ,
Consumer Complaint System ,
Consumer Financial Products ,
Consumer Financial Protection Bureau (CFPB) ,
Consumer Lenders ,
Credit Cards ,
Credit Reporting Agencies ,
Debt Collection ,
Financial Services Industry ,
Military Service Members ,
Mortgages
The FTC has launched a new page on its website dedicated to its Military Task Force. According to the FTC, it created the Task Force “to focus on identifying the particular needs of military consumers and developing...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
The U.S. Department of Justice (DOJ) announced last week that it reached an agreement with Michigan-based COPOCO Community Credit Union to settle a lawsuit alleging that the credit union violated the Servicemembers Civil...more
On July 19, the Federal Trade Commission will hold a workshop in San Antonio titled the “2017 Military Consumer Financial Workshop: Protecting Those Who Protect Our Nation.” The FTC has uploaded an agenda and list of...more
6/23/2017
/ Automotive Loans ,
Banking Sector ,
Consumer Financial Products ,
Consumer Financial Protection Bureau (CFPB) ,
Debt Collection ,
Federal Trade Commission (FTC) ,
Financial Fraud ,
Financial Literacy ,
Financial Services Industry ,
Military Service Members ,
Student Loans ,
Veterans
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
According to an announcement posted on the Servicemembers Civil Relief Act Website, “[a] bug in the SCRA website is causing the site to give false negatives for some National Guard members whose service should be positively...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