Removing Barriers Blog

MLA Update: CUNA and DCUC Meet with DoD Officials and Deliver Bipartisan Letter

CUNA Chief Compliance Officer Jared Ihrig joined with the Defense Credit Union Council for a meeting with the Department of Defense (DoD) to reiterate credit union concerns and urge for more clarification for member credit unions on the changes to the MLA that are set to become effective in less than three weeks.  

The changes to the MLA were finalized in July 2015, expanding the types of loans covered by the rule and establishing limitations on terms of consumer credit extended to servicemembers and their dependents. Many changes became effective in October 2016, and credit card provisions changes will become effective on October 3, 2017. 

CUNA has been seeking guidance from the DoD on the MLA changes for many months.  As said in the past, credit unions deserve clear guidance on how they can continue to service their servicemembers and their families without running into trouble due to the MLA.  Since December, CUNA has sent four letters to the DoD – and has yet to receive an adequate response.  

During the meeting, CUNA and DCUC again urged the DoD to issue guidance as soon as possible on the areas of concern covered in the previous letters.  Jared Ihrig also noted, "Department officials also indicated they have been consulting with other federal banking regulators, including NCUA and the Consumer Financial Protection Bureau, in developing additional guidance, and hope to meet with federal banking regulators near the end of October to further assess efforts of the regulatory implementation process by affected creditors and financial institutions."  

In addition to attempting to work with the DoD, CUNA has also been engaging with Members of Congress on this issue as well.  With strong support from CUNA, House Armed Services Committee Member Rep. Paul Cook circulated a Dear Colleague letter to request the DoD to exempt credit unions from its MLA regulation.  Prior to the meeting, a bipartisan group of lawmakers sent the letter to the DoD urging for MLA relief. In the letter, the lawmakers noted specifically their concerns with how credit unions have been forced to cut back on product and service offerings as a result of the changes. 

CUNA greatly appreciates Representative Cook and the other letter cosigners for their interest and determination to help credit unions attain regulatory relief and continue to provide critical services to our nation’s brave servicemembers and their families.