Removing Barriers Blog

CFPB Releases Updated Exam Procedures for MLA
Posted September 30, 2016 by CUNA Advocacy

Today, the CFPB released updated examination procedures for the Military Lending Act rule as amended in July of 2015. The release, MLA Interagency Examination Procedures—2015 Amendments, provides guidance on what the CFPB will be looking for during reviews covering the amended regulation, which goes into effect next month. 


While today’s release provides insight into what CFPB examiners will use in identifying consumer harm and risks related to the MLA rule, it does not address lingering issues and unanswered questions CUNA has raised with the Department of Defense and NCUA. 


Specifically, in a letter earlier this month to NCUA Chairman Metsger, we asked the agency to clarify a number of issues related to the MLA rule, including issues related to purchase money loans, ancillary products, statutory liens, the definition of “vehicle,” and the possibility of a safe harbor. Last week, CUNA met with NCUA staff to discuss these and other items of concern. 


The letter to NCUA follows a letter we sent to DoD in late August urging a minimum six-month delay of the October 3 effective date of the MLA regulation. In the absence of a delayed effective date, that letter sought a safe harbor of at least six months for lenders that are working to comply with the rule but are unable to do so by October 3.