News & Analysis as of

Military Lending Act

New Federal Bills Feature MLA Requirements, AML Obligations

New legislation recently introduced in Congress impacting the financial services industry would amend the Military Lending Act (MLA) and impose additional requirements with regard to anti-money laundering (AML) obligations....more

Propoposed Bill Would Significantly Expand MLA Disclosure Requirements

by Ballard Spahr LLP on

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

Proposed Bill Would Require Disclosures to Servicemembers Regarding Lower Cost Credit

by Ballard Spahr LLP on

On May 25, Congressman Dan Kildee (D-Michigan) referred a bill to the House Committee on Armed Services titled the “Transparency in Military Lending Act of 2017.” ...more

Credit Card Issuers Get Ready – MLA in Full Effect October 3

by Baker Donelson on

Credit card issuers get ready; now is the time to make sure you are in compliance with the new requirements of the Military Lending Act (MLA). The amendments to the MLA expanded both the type of creditors it regulates and the...more

CFPB’s Office of Servicemember Affairs Issues Annual Report

by Ballard Spahr LLP on

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

Banking & Financial Services E-Note - February 2017

by Burr & Forman on

The White House clarified that Trump’s January 30 “two for one” Executive Order doesn’t apply to the SEC and other independent regulatory agencies, Reuters reported. Despite press coverage, the Order doesn’t actually require...more

MLA Website malfunction

by Ballard Spahr LLP on

According to an announcement posted on the Military Lending Act (“MLA”) Website, “[b]etween February 9, 2017 and February 15, 2017 there was a problem with MLA Multiple Record Requests that prevented 149 request files from...more

Military Lending Act Compliance

by Burr & Forman on

On October 3, 2017, the Department of Defense’s revised Military Lending Act (“MLA”) regulations will apply to consumer credit card accounts. These regulations require significant changes and will alter the landscape of how...more

CFPB settles with military financing company for alleged TILA/EFTA disclosure violations

by Ballard Spahr LLP on

The CFPB announced that it has entered into a consent order with Military Credit Services, LLC, a company providing revolving credit to military consumers, to settle allegations that the company’s open-end credit agreements...more

Financial Services Report, Winter 2016

by Morrison & Foerster LLP on

EDITOR’S NOTE - Hope you survived all of those awkward Thanksgiving holiday conversations— amazing how divided people are on whether the court got it right in the PHH case, isn’t it? So on we go into the holiday season,...more

CFPB to participate in interagency MLA webinar

by Ballard Spahr LLP on

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

FTC continues vigorous use of enforcement authority

by Ballard Spahr LLP on

As observers ponder the CFPB’s future in a Trump Administration, the Federal Trade Commission’s continuing role as an enforcer of federal consumer financial protection laws should not be overlooked. Over the approximately...more

Takeaways from the Admiralty Law Institute-Maritime Law Association 50-Year Reunion

Last week, 425 admiralty and maritime lawyers, law professors, U.S. Coast Guard officers, law students, and maritime industry professionals descended on New Orleans for the Golden Rules: Tulane Admiralty Law Institute and...more

FDIC Releases Revised MLA Exam Procedures and Sets Supervisory Expectations

by Ballard Spahr LLP on

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

CFPB: The Quarterly Review, Q3 2016

by White & Case LLP on

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

by Ballard Spahr LLP on

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

Financial Services Weekly News - October 2016

by Goodwin on

Editor's Note - Regulation and Innovation, Part IV. In the April 6, June 22 and September 14 editions of the Roundup, we discussed the approaches of various banking regulators generally, and the Office of the...more

DoD Publishes Guidance on MLA Amendments

With the July 2015 amendments to the Military Lending Act (MLA) set to take effect on October 3, the Department of Defense (DoD) published an interpretive rule to help financial institutions achieve compliance with the...more

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

by Morrison & Foerster LLP on

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

DoD issues MLA interpretive rule

by Ballard Spahr LLP on

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

by Ballard Spahr LLP on

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

by Ballard Spahr LLP on

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

by Morrison & Foerster LLP on

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

Short-Term Lenders Face Costly Path To Compliance

by Morrison & Foerster LLP on

On June 2, 2016, the Consumer Financial Protection Bureau released its long-anticipated notice of proposed rulemaking on short-term consumer lending. The proposed rule follows the CFPB’s March 2015 release of an outline of...more

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