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Regulatory Advocacy

Working Together to Reduce Regulatory Burdens
Regulation Summary
Agency Department of Defense (DOD)
Rule Name DOD Proposed Rule re Military Lending Act
Comment Due Date 11/28/14

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PowerComment
  • 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.