Consumer Protection Military

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FDIC Releases Revised MLA Exam Procedures and Sets Supervisory Expectations

On October 17, the FDIC released revised interagency Military Lending Act (MLA) examination procedures for use in connection with consumer credit transactions occurring on or after October 3, 2016. The revised procedures...more

Creditors and Debt Collectors Should Pay Close Attention to the CFPB’s Consent Order with Navy Federal Credit Union

The Consumer Financial Protection Bureau (CFPB) announced a consent order with Navy Federal Credit Union (Navy Federal) on October 11, 2016. While financial institutions should always analyze CFPB consent orders closely and...more

CFPB: The Quarterly Review, Q3 2016

White & Case’s Financial Institutions Advisory (FIA) practice is pleased to share its most recent quarterly newsletter on the Consumer Financial Protection Bureau’s ("CFPB” or "Bureau”) oversight of the consumer financial...more

CFPB enters into consent order with credit union

The CFPB announced that it has entered into a consent order with Navy Federal Credit Union to settle allegations that the credit union engaged in unfair and deceptive collection practices in violation of the Consumer...more

CFPB Settles with National Credit Union Over Alleged Deceptive Debt Collection Practices

On October 11, the Consumer Financial Protection Bureau (CFPB) announced that it entered into a consent order with a national credit union over allegations that the credit union made false and misleading representations to...more

CFPB and FFIEC Release Updated MLA Exam Procedures; NCAU Will Accept Reasonable and Good Faith Efforts to Comply

On September 30, the CFPB released updated examination procedures for Military Lending Act (MLA) compliance. Compliance with the final rule amending the MLA, issued by the Department of Defense (DoD) in July 2015, was...more

SCRA website malfunctioning

According to an announcement posted on the Servicemembers Civil Relief Act Website, “[a] bug in the SCRA website is causing the site to give false negatives for some National Guard members whose service should be positively...more

A Closer Look at DOD’s New Guidance on the Military Lending Act Regulations

On August 26, 2016, the Department of Defense (“DOD”) issued an interpretive rule (the “Interpretive Rule”) providing guidance on the DOD’s regulations implementing the Military Lending Act (“MLA”). That same day, we...more

Ballard Spahr partner Dee Spagnuolo joins CFPB OMWI Director on panel at ABA meeting

Members of Ballard Spahr’s Consumer Financial Services group recently participated in the American Bar Association Business Law Section Annual Meeting held in Boston, Massachusetts. On September 8, Ballard partner, Dee...more

DoD issues MLA interpretive rule

The Department of Defense (DoD) has issued an interpretive rule to assist the industry in complying with its July 2015 final rule amending the Military Lending Act’s implementing regulation. The much-anticipated guidance was...more

Trade groups seek extension of compliance date for Military Lending Act final rule

The American Bankers Association, joined by six other prominent industry trade groups, is seeking a six-month extension of the date by which depository institutions must comply with the Military Lending Act (MLA) final rule...more

Holly Petraeus to retire from CFPB

According to Politico, Holly Petraeus, Assistant Director of the CFPB’s Office of Servicemember Affairs, will be retiring from the CFPB. During her tenure at the CFPB, the protection of military servicemembers and their...more

Department of Defense Issues New Guidance on Military Lending Act Regulations

On August 26, 2016, the Department of Defense (DOD) issued an interpretive rule providing guidance on the DOD’s regulations implementing the Military Lending Act (MLA). Specifically, the interpretive rule aims to clarify...more

Defense Database for Military Status of Borrower Still a Work in Progress

Lenders and servicers seeking to comply with the Servicemembers’ Civil Relief Act (SCRA) who depend on the commonly used Defense Manpower Data Center (DMDC) database have a little more comfort now on the accuracy of their...more

Pennsylvania AG Sues Financial Services Company for Defrauding Veterans

On May 5, 2016, the Pennsylvania Attorney General announced the filing of a civil lawsuit in the Clinton County (PA) Court of Common Pleas against an Ohio financial services company and its owner for misleading at least four...more

CFPB seeking comment on new repayment plan disclosures for federal student loan borrowers

The CFPB has issued a Request for Information (RFI) seeking comment on a set of prototype disclosures to assist federal student loan borrowers in selecting between alternative repayment plans.  Comments are due on or before...more

CFPB: The Quarterly Review - April 2016

If the first quarter is any indication, 2016 is going to be a busy year for the CFPB and market participants alike. The CFPB Speaks - Regulation by enforcement - On March 9, during his prepared remarks to...more

SCRA Will Continue to Receive Regulatory Scrutiny

On March 22, 2016, the U.S. House of Representatives passed the Foreclosure Relief and Extension for Servicemembers Act of 2015. This bill was signed into law by President Obama on March 31, 2016. This follows the...more

Trade groups seek clarifications to Military Lending Act regulations

A number of prominent industry trade groups have written to the Department of Defense (DoD) seeking clarifications to the Military Lending Act (MLA) final rule adopted in July 2015 that dramatically expanded the scope of the...more

Overview of Financial Protections for Military Service Members, Including the New Military Lending Act

The U.S. Department of Defense (“DOD”) has put into effect the newly amended Military Lending Act (“MLA”) rule, which applies the protections of the MLA’s strict lending restrictions to consumer credit card issuers and...more

CFPB issues fourth annual report on servicemember complaints

The CFPB’s Office of Servicemember Affairs released its fourth annual report highlighting complaints submitted in 2015 by servicemembers, veterans, and their families. The report states that in 2015, the CFPB received...more

Deadline Extended for Requesting Direct Access to Military Loan Act Database

The Department of Defense has extended the deadline for requesting direct access to its Military Loan Act (MLA) Defense Manpower Data Center (DMDC) database until February 15, 2016. Under amendments to the MLA's implementing...more

Congress Enacts Major Cybersecurity Legislation

On December 18, 2015, Congress passed, and the President signed, the Cybersecurity Act of 2015, which provides authorization and liability protection for cybersecurity monitoring and information-sharing and authorization for...more

Back-Door Access to Encrypted Communications: Weakening Security to Improve Security?

Last month’s terror attacks in Paris have re-ignited the long-standing debate between national security and privacy advocates over whether technology companies should be required to provide the government special access to...more

Cyberattack Prevention, Assessment, And Response Is A Key Focus In Intelligence Authorization Bill Passed By The House

On December 1, 2015, the U.S. House of Representatives passed a revised Intelligence Authorization Act. The White House had threatened to veto a previous version of the bill, but proponents of the passed version say that...more

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