Archive

IMMEDIATE CHANGES TO THE MLA WEBSITE

On June 27, 2019, the Defense Manpower Data Center (DMDC) will make significant changes to the Military Lending Act (MLA) website to enhance security of the site and better protect the personal information of Service members. All users of the site will be required to create user accounts. A user account will be required to access both the Single Record Request and the Multiple Record Request capabilities of the MLA site. No search for active service […]

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MILITARY LENDING ISSUES

What’s going on with military lending? Is there a pattern we should be watching? On January 17, 2019 the Consumer Financial Protection Bureau (CFPB) announced that it has asked Congress to grant the agency clear authority to supervise for compliance with the Military Lending Act (MLA). On January 24, 2019 the CFPB announceda settlement a broker of contracts offering high-interest credit to veterans. The Consent Order filed by the CFPB states that the Bureau found the […]

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LATE YEAR SERVICEMEMBER REVISIONS

Laws that impact lending to servicemembers include the Military Lending Act and the Servicemembers Civil Relief Act. Both laws have been recently amended. Both sets of amendments bring clarity to areas of uncertainty. In response to these recent changes all creditors need to update their compliance management systems. Changes to policies, procedures, audit and training are needed to assure continued compliance. The revisions are already effective. Servicemembers Civil Relief Act (SCRA) On December 12, 2017 […]

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MLA GUIDANCE PUBLISHED

On December 14, 2017 the Department of Defense (DoD) published some much needed clarification on the Military Lending Act (MLA). Previous DoD interpretations, in the form of 19 Questions and Answers published during August 2016,  provided less than sufficient answers to certain questions. The new guidance eliminates much of the confusion on those issues by amending its guidance on three of the questions and by providing one additional question and answer. Question 2 is amended […]

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MILITARY LENDING ACT EXAMINATION PROCEDURES

On October 17. 2016 the FDIC released revised interagency examination procedures that reflect the Department of Defense’s (DOD) 2015 amendments to the implementing regulations of the Military Lending Act of 2006 (MLA) and its August 2016 interpretive rule that provides guidance on certain questions received regarding compliance with the MLA rule. During early examinations, examiners will evaluate financial institutions’ compliance management systems and overall efforts to come into compliance. Specifically, examiners will consider an institution’s […]

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