Removing Barriers Blog

Review of MLA Guidance Identifies Concerns
Posted December 18, 2017 by CUNA Advocacy

As reported last week, the DoD released long-awaited guidance on the Military Lending Act that amends three comments included in last year’s DoD guidance and adds one additional comment. While CUNA pushed the DoD to develop such guidance, particularly in light of confusion surrounding the rule’s credit card provisions, last week’s release falls short.

The guidance does not address any issues related to the rule’s credit card provisions. In addition, it appears to create some confusion regarding the rule’s application to ancillary credit products in certain transactions.

We will continue to work with the DoD to seek clarification on the issues we’ve raised on several occasions over the past few years.

Visit CUNA’s Compliance Blog for a thorough review of the recent guidance.