News & Analysis as of

CFPB to participate in interagency MLA webinar

On December 1, 2016, the  FDIC will co-host an interagency webinar that will focus on Military Lending Act regulations and the Department of Defense’s recently-released interpretive rule. In addition to a CFPB...more

As part of joint initiative with the CFPB, FTC launches updated, mobile-friendly Military Consumer website

This week, the FTC announced the launch of a redesigned Military Consumer website as part of its joint initiative with the DoD, CFPB and others. Military.Consumer.gov is a financial readiness website designed to help...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

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

In Case You Missed It: Launch Links - June 2016

Some interesting links we found across the web this week: Congressional Panel To Investigate The Fairness Of Pay TV Billing, Competitive Practices - There was plenty of startup news out of DC this week, starting...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

Privacy & Cybersecurity Update - March 2016

In this edition of our Privacy & Cybersecurity Update, we examine the FCC's proposed privacy rules for broadband providers; new developments relating to the Privacy Shield, which was created to replace the U.S.-EU Safe Harbor...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

Government Forces Awaken: The Rise of Cyber Regulators in 2016

As the sun sets on 2015, but before it rises again in the New Year, we predict that, in the realm of cyber and data security, 2016 will become known as the “Rise of the Regulators.” Regulators across numerous industries and...more

Jumping To Judgment on For-Profit Education

If you didn’t know any better, you might have gotten pretty fiery over for-profit education after reading one of the front page stories of Tuesday’s New York Times. The lengthy article titled “For-Profit Colleges Fail...more

CFPB Releases Outline of Proposals to Block Pre-Dispute Arbitration Agreements in Class Litigation

On October 7, 2015, the Consumer Financial Protection Bureau (“CFPB” or the “Bureau”) released an outline of proposals under consideration to ban class action waivers in contracts for consumer financial products and services....more

DoD Releases Final Military Lending Act Regulations

The Department of Defense (DoD) released its final rule amending the implementing regulations of the Military Lending Act (MLA), incorporating a broader range of credit products under its coverage and potentially implicating...more

Department of Defense Adopts Significant Changes to Its Military Lending Act Regulations

On July 22, 2015, the Department of Defense (DOD) published sweeping changes to its rules that implement the Military Lending Act (MLA). The amended rules significantly expand the scope of the MLA provisions by covering both...more

Defense Department Dramatically Expands Scope of Military Lending Act

The Department of Defense (DoD) dramatically expanded the scope of the Military Lending Act (MLA) on July 22, 2015, publishing its Final Rule amending the MLA’s implementing regulation. MLA coverage was previously limited to...more

Department of Defense Issues Final Rule Expanding Military Lending Act to Credit Cards and Other Consumer Lending Products

On July 21, 2015, the U.S. Department of Defense (“DOD”) announced the final rule amending the Military Lending Act’s (“MLA”) implementing regulations. The changes apply the MLA’s strict lending restrictions to consumer...more

CFPB sends warning letters on military allotment practices

The CFPB announced that it sent warning letters this month to several companies that sell retail goods to military servicemembers regarding their acceptance of payments made through military allotments. The military...more

Director Cordray appears before Senate Banking Committee

On Wednesday, July 15, CFPB Director Richard Cordray appeared before the Senate Committee on Banking, Housing, & Urban Affairs to answer questions regarding the Bureau’s Semi-Annual Report to Congress and the President, which...more

Proposed MLA expansion in limbo

Despite the CFPB’s efforts to build support for the Department of Defense’s proposal to significantly expand Military Loan Act coverage, it now appears that the proposal may be put on hold. The DoD proposal would revise the...more

ABA criticizes CFPB study on high-cost credit extended to servicemembers

The American Bankers Association has sent a letter to the Department of Defense “to alert the Department to shortcomings” in the CFPB’s study entitled “The extension of high-cost credit to servicemembers and their families”...more

CFPB Weighs in on Department of Defense Military Lending Act Proposed Rule

On December 29, 2014, the Consumer Financial Protection Bureau (CFPB) released a report, entitled “The Extension of High-Cost Credit to Servicemembers and Their Families” (“Report”). According to the CFPB, the Report provides...more

CFPB endorses MLA expansion

In an effort to build support for the Department of Defense’s proposal to significantly expand Military Loan Act coverage, the CFPB has released a report entitled “The extension of high-cost credit to servicemembers and their...more

CFPB praises change in military discretionary allotment system

CFPB Assistant Director for Servicemember Affairs Holly Petraeus has issued a statement applauding changes to the military discretionary allotment system announced last week by the Department of Defense (DoD). The...more

DOD Proposes Significant Expansion of Military Lending Act Protections

On September 29, 2014, the Department of Defense (DOD) published a proposed rule in the Federal Register to amend its regulation implementing the Military Lending Act (MLA), 32 C.F.R. Part 232, to significantly expand the...more

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