Working Together to Reduce Regulatory Burdens
||Department of Defense (DOD)
||DOD Proposed Rule re Military Lending Act
|Comment Due Date
- The Department of Defense (DOD) recently issued a proposal to amend its rule that implements the Military Lending Act (MLA). The proposal would significantly expand the scope of products covered by the MLA, including credit cards.
- Specifically, the proposal would amend “consumer credit” to extend the definition to a broader range of closed-end and open-end credit products; the proposed definition is consistent with that of the Truth-in-Lending-Act (TILA), as implemented by the CFPB’s Regulation Z.
- The proposal would also amend provisions of DOD’s rule regarding the manner in which a creditor can assess whether a consumer is a “covered borrower.”
- In addition, the proposal would modify disclosures that a creditor must provide a covered borrower, as well as implement enforcement provisions of the MLA.
- CUNA continues to work with the Defense Credit Union Council (DCUC), leagues, and credit unions. DOD is accepting comments until November 28; please send comments to CUNA by November 7.
- Please contact CUNA Senior Assistant General Counsel Luke Martone with any questions please contact.