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 […]
Tag: Military Lending Act
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 […]
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 […]