Removing Barriers Blog

Credit Card Provisions of MLA Regulation to Take Effect as Scheduled

Today, the DoD responded to a June 21 letter  sent jointly by CUNA and several other financial trade associations detailing ongoing issues with the Military Lending Act regulation regarding extensions of credit to servicemembers and their families. In addition to describing specific corrections that the DoD could implement to clarify a number of issues in the regulation, the June letter requested a delay of the credit card-related provisions of the regulation that become effective tomorrow (October 3).

We are disappointed that the DoD has decided to not issue a delay of the credit card provisions. Further, we are disappointed that the DoD chose to wait until the last few hours before the provisions become effective to announce its decision. Credit unions and their vendors, as well as other financial service providers, continue to have questions regarding implementation of these provisions. 

In today’s letter, the DoD did confirm that it is “presently working to provide additional clarifying guidance on a number of items highlighted in [the joint] letter through an Interpretive Rule Amendment.” While we are hopeful the clarifying guidance will address the issues we’ve raised over the past year with the DoD regarding the MLA regulation—both related and unrelated to the credit card provisions—it will be of limited use in assisting the industry to prepare by the effective date. However, we will analyze the guidance once it is released and continue to press the DoD for further clarification, if necessary.