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 new types of creditors and new credit products, including installment loans and other closed-end credit products and credit cards and other open-end credit accounts. The rules become effective on October 1, 2015, with compliance required by October 3, 2016. However, compliance with the rules for credit cards is delayed until October 3, 2017, unless extended for an additional year until October 3, 2018.

BACKGROUND -

In general, the MLA and DOD implementing rules apply to active duty service members and their spouses or dependents. Under the prior DOD rules, the provisions applied to only a narrow range of consumer credit products—“payday” loans, vehicle title loans and refund anticipation loans.