On August 26 the Department of Defense (DOD) published 19 questions and answers concerning the requirements of the Military Lending Act and its Part 232. Many questions have swirled around the provisions of Part 232 for some now. Some of the questions are clearly answered in the document; other answers are quite fuzzy. The questions and answers represent official interpretations of the DOD on issues related to 32 CFR part 232. The interpretations are effective […]
Category: Department of Defense
DEADLINE QUICKLY APPROACHING FOR KEY ISSUE OF MILITARY LENDING ACT
And yet another regulatory deadline is approaching in 2016…the final rule that amends existing Part 232 implementing the Military Lending Act has a mandatory compliance date of October 3, 2016. I know you may be thinking, October is still a long way away; we will worry about that one later. Not so fast Batman, another deadline relating to this regulatory change occurs this month, in fact only 5 calendar days from today – February 15, […]
CHANCE TO BREATHE
I lot of people seemed to think that once the August 1 TRID deadline arrived life would be much easier. Well today is August 1, and the future doesn’t look any easier. TRID has been delayed until October 3, 2015; New interagency flood insurance regulations are effective, in large part, on October 1, 2015, with the new escrow rules unfolding on January 1, 2016; The new Military Lending Act regulations, which look like the real […]
NEW MILITARY LENDING ACT REGULATIONS
On July 21 the Department of Defense (DOD) published a final rule revising Part 232, which implements the Military Lending Act (MLA). The new rules will impact most lenders. The Military Lending Act became law in 2006. Part 232 was effective on October 1, 2007. While the MLA appeared to apply very broadly, Part 232 severely restricted coverage. Most lenders have not paid much attention to the existing regulations due to limits on the types […]