Removing Barriers Blog

CUNA Urges DOD to Issue Guidance on MLA

CUNA and other representatives from the Financial Industry met Wednesday with representatives from the Department of Defense and all Federal Financial Regulatory Agencies (NCUA, CFPB, FTC, FDIC, OCC, FRB) to reiterate the numerous concerns with the Military Lending Act (MLA) regulation.  Specifically discussed were the following: 

  1. Supplementary information’s inaccurate calculation of MAPR for open-end loans; 

  1. Limits on fees during periods where there is no balance; 

  1. Exemption of purchase money loans; 

  1. Prohibition against liquid (share) secured loans; 

  1. Right of offset/statutory liens; 

  1. Use of remotely created checks for payment; 

  1. Method of providing oral disclosures; and 

  2. Issues with the upcoming credit card requirements set to become effective October 3, 2017.

The Agencies were open to hearing the challenges arising under the MLA and the upcoming credit card regulatory deadline.  While they did not commit to any solutions at the meeting, all agencies indicated their willingness to find solutions and work with industry on the implementation issues.  CUNA intends to follow up with the agencies to seek additional guidance and clarifications pertaining to these and other issues under the MLA in the very near future.