On February 28, 2020, the Department of Defense (DOD) published and made effective amendments to its interpretive rule related to the Military Lending Act (MLA). The MLA, which has undergone numerous revisions over the past several years, provides protection to servicemembers and their dependents by limiting the military annual percentage rate (MAPR) that a creditor may charge to a maximum of 36 percent and requiring disclosures among other consumer protections. Revisions to the MLA regulations […]
Category: Military Lending Act
IMMEDIATE CHANGES TO THE MLA WEBSITE
On June 27, 2019, the Defense Manpower Data Center (DMDC) will make significant changes to the Military Lending Act (MLA) website to enhance security of the site and better protect the personal information of Service members. All users of the site will be required to create user accounts. A user account will be required to access both the Single Record Request and the Multiple Record Request capabilities of the MLA site. No search for active service […]
MILITARY LENDING ISSUES
What’s going on with military lending? Is there a pattern we should be watching? On January 17, 2019 the Consumer Financial Protection Bureau (CFPB) announced that it has asked Congress to grant the agency clear authority to supervise for compliance with the Military Lending Act (MLA). On January 24, 2019 the CFPB announceda settlement a broker of contracts offering high-interest credit to veterans. The Consent Order filed by the CFPB states that the Bureau found the […]
LATE YEAR SERVICEMEMBER REVISIONS
Laws that impact lending to servicemembers include the Military Lending Act and the Servicemembers Civil Relief Act. Both laws have been recently amended. Both sets of amendments bring clarity to areas of uncertainty. In response to these recent changes all creditors need to update their compliance management systems. Changes to policies, procedures, audit and training are needed to assure continued compliance. The revisions are already effective. Servicemembers Civil Relief Act (SCRA) On December 12, 2017 […]
MLA GUIDANCE PUBLISHED
On December 14, 2017 the Department of Defense (DoD) published some much needed clarification on the Military Lending Act (MLA). Previous DoD interpretations, in the form of 19 Questions and Answers published during August 2016, provided less than sufficient answers to certain questions. The new guidance eliminates much of the confusion on those issues by amending its guidance on three of the questions and by providing one additional question and answer. Question 2 is amended […]