News & Analysis as of

Military Lending Act Consumer Financial Protection Bureau (CFPB) Department of Defense (DOD)

Ballard Spahr LLP

Military Lending Act violations alleged against title lender in Georgia class action

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A proposed class action lawsuit filed in the U.S. District Court for the Northern District of Georgia on February 21, 2024 against TitleMax of Georgia, Inc. and TMX Finance LLC (together, “TitleMax”) accuses the Georgia-based...more

Hudson Cook, LLP

Federal Agencies Take Another Shot at GAP Coverage for Buyers Covered by the Military Lending Act

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I have always been a fan of suspenseful entertainment. I really like television shows where it looks like the protagonist is doomed, but then escapes, lands back in trouble, and gets out ... again! So fun. Originally...more

Hudson Cook, LLP

CFPB Announces Broad Military Lending Act Compliance Sweep

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On December 4, 2020, the Consumer Financial Protection Bureau announced the filing of a lawsuit against an online lender for allegedly violating the Military Lending Act ("MLA"). The CFPB's complaint alleges that the lender...more

Ballard Spahr LLP

Department of Defense Reverts to Prior Position on MLA Interpretive Rule Q&A #2 Regarding Motor Vehicle and Personal Property...

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In a new interpretive rule published on February 28, 2020, the Department of Defense (DoD) has announced that it is withdrawing guidance previously issued in its December 14, 2017 Interpretive Rule, Q&A #2, governing motor...more

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Update to MLA Website Expands Search Functionality

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Yesterday, the Department of Defense’s (DoD) Military Lending Act website was temporarily taken offline to accommodate various “security and performance enhancements.” ...more

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Trade groups ask Defense Dept. to rescind MLA interpretation on GAP insurance financing

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Four trade groups have sent letters to the Department of Defense (DoD) asking the DoD to rescind or withdraw Question and Answer #2 (Q&A 2) from its 2016 interpretative rule for the Military Lending Act final rule (MLA Rule)...more

Ballard Spahr LLP

Department of Defense Issues Additional MLA Rule Interpretive Guidance; SCRA Foreclosure Protections Extended

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Last week the Department of Defense (DoD) issued an interpretive rule under the DoD’s Military Lending Act final rule (MLA Rule). The interpretive rule amends four of the “Q&A” format interpretations that DoD issued on August...more

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MLA Compliance Deadline For Credit Card Accounts Is Tuesday, October 3

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The Military Lending Act (MLA) will apply to credit card accounts starting Tuesday, October 3. The final rule took effect last October but provided a one-year exemption for “credit extended in a credit card account under an...more

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Defense Dept. rejects trade group’s request for extension of Oct. 3 MLA compliance date for credit cards

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The Department of Defense (DoD) is reported to have rejected the request of the National Association of Federally-Insured Credit Unions (NAFCU) to extend the October 3, 2017 date for credit card compliance with the Military...more

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Propoposed Bill Would Significantly Expand MLA Disclosure Requirements

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We recently reported on a bill introduced in the House of Representatives by Congressman Dan Kildee (D-Michigan) that would amend the Military Lending Act (“MLA”) to require that creditors provide additional disclosures to...more

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CFPB’s Office of Servicemember Affairs Issues Annual Report

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The CFPB’s Office of Servicemember Affairs (OSA) has issued its fifth annual report to Congress addressing issues raised and complaints submitted by servicemembers, veterans, and their families....more

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CFPB to participate in interagency MLA webinar

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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

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

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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

Ballard Spahr LLP

DoD issues MLA interpretive rule

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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

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

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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

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Holly Petraeus to retire from CFPB

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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

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Trade groups seek clarifications to Military Lending Act regulations

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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

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Deadline Extended for Requesting Direct Access to Military Loan Act Database

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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

WilmerHale

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

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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

Manatt, Phelps & Phillips, LLP

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

Morrison & Foerster LLP

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

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Defense Department Dramatically Expands Scope of Military Lending Act

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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

WilmerHale

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

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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

Ballard Spahr LLP

Director Cordray appears before Senate Banking Committee

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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

Ballard Spahr LLP

Proposed MLA expansion in limbo

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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

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