The Department of Defense (DOD) has posted a news update on its Military Lending Act (MLA) website informing users of the following: “Between February 9, 2017 and February 15, 2017 there was a problem with MLA Multiple Record Requests that prevented 149 request files from processing. If you submitted a Multiple Record Request file between 9 and 15 February that failed to process, please submit the file again for processing.” Under the MLA covered borrowers […]
Category: Military Lending Act
MILITARY LENDING ACT EXAMINATION PROCEDURES
On October 17. 2016 the FDIC released revised interagency examination procedures that reflect the Department of Defense’s (DOD) 2015 amendments to the implementing regulations of the Military Lending Act of 2006 (MLA) and its August 2016 interpretive rule that provides guidance on certain questions received regarding compliance with the MLA rule. During early examinations, examiners will evaluate financial institutions’ compliance management systems and overall efforts to come into compliance. Specifically, examiners will consider an institution’s […]
COUNTDOWN TO THE MILITARY LENDING ACT
In one week, on October 3, 2016, compliance with the revisions to Part 232, which implements the Military Lending Act (MLA), is mandatory. The revised rules were effective on October 1, 2015. but the revised provisions do not apply to credit consummated before October 3, 2016. For any covered transaction consummated on or after October 3, 2016 the creditor must provide required disclosures, assure the Military Annual Percentage Rate does not exceed 36%, and abide […]
MLA QUESTIONS AND ANSWERS
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 […]
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, […]