Removing Barriers Blog

CUNA Continues to Push for Clarity on MLA Guidance
Posted September 20, 2018 by CUNA Advocacy

Today, CUNA sent a follow-up letter to the Department of Defense and Office of Management and Budget, seeking resolution to the ongoing issue with Question & Answer 2 (QA2) of the DoD’s December 2017 guidance on the MLA rule. Specifically, QA2, which addresses certain credit extended for the purchase of a motor vehicle or personal property, has caused confusion and compliance challenges for lenders since it was issued. We have been working with the DoD since early this year to remedy the problematic language in the guidance.

We were glad to hear that the DoD has agreed to a “fix” to QA2 and has provided that change to the OMB for review prior to publication in the Federal Register. However, it is unclear why it has taken so many months to push this innocuous change through the process. We hope this latest letter will speed up the process of finalizing the change or at a minimum will provide us with information on the reason for the delay.