Removing Barriers Blog

DoD MLA Guidance Falls Short
Posted August 25, 2016 by CUNA Advocacy

The US Department of Defense (DoD) has released much-awaited guidance intended to aid in compliance with the Military Lending Act regulation that was adopted last summer. The guidance, available here, will be published in tomorrow’s Federal Register. 
 
CUNA and other trade associations pushed DoD for months to release comprehensive guidance by spring of this year. While some of the guidance does appear helpful, based on an initial review, it seems as though it may be "too-little, too-late." 

The guidance does not appear to define key terms, such as “ancillary product.” With the October 3rd effective date quickly approaching, it is critical that credit unions and their core processors review the guidance in detail to fully understand how to comply with the rule’s new requirements.

Our Compliance Team will be putting out a thorough analysis of this guidance on its CompBlog soon.