Removing Barriers Blog

DoD Releases Long-Awaited MLA Guidance
Posted December 13, 2017 by CUNA Advocacy

The DoD has released long-awaited guidance on the Military Lending Act that will be published in tomorrow’s Federal Register. The guidance amends three comments included in last year’s DoD guidance and adds one additional comment.

Since the MLA rule was first proposed in 2014, CUNA has been very active with the DoD in an effort to influence the final rule, adopted in July 2015, and to subsequently reform the final rule through amendments and interpretive guidance. Most recently, CUNA President & CEO Jim Nussle met with current OMB Director Mulvaney to discuss ongoing credit union concerns with the MLA regulation, focusing on the now-released guidance, which had been awaiting OMB approval.

CUNA has pressed the DoD for updated guidance numerous times over the past year; DoD issued an initial guidance document in August of 2016. Prior to Nussle’s meeting with Director Mulvaney, CUNA, together with the Defense Credit Union Council, met with DoD earlier this Fall to reiterate credit union concerns and urge for more clarification for member credit unions. In addition to working with the DoD, CUNA has been engaged with Members of Congress on this issue. This work resulted in a September letter by a bipartisan group of representatives to the DoD highlighting concerns shared by CUNA about unintended consequences of the rule.

We are still reviewing the guidance to determine its impact, and will provide a detailed analysis in CUNA’s Compliance Blog in the coming days.