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Department of Defense (DOD) Consumer Financial Products

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

Fourth Circuit Takes Expansive View of MLA Auto-Loan Exemption

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In a decision highly anticipated by the auto finance industry, a federal appeals court recently held that auto loans remain exempt from the Military Lending Act even when they finance related costs or services beyond the...more

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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

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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

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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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Department of Defense Proposes Data Sharing Arrangement with Department of Education to Identify Service Members Eligible for 0%...

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A Federal Register entry published last week details a proposed data-sharing arrangement between the Department of Defense (DoD) and the Department of Education (DoE) designed to reduce the amount of interest that certain...more

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Trump Administration Plans to End Military Lending Act Prohibition on Offering GAP Insurance to Service Members in Auto Loan...

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NPR reported last week that the Trump Administration is planning to end the current prohibition under the Military Lending Act (“MLA”) against creditors offering service members GAP insurance in connection with credit...more

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More industry groups petition Department of Defense to withdraw MLA interpretation on GAP insurance financing—is a response...

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We previously reported that several trade groups had sent letters petitioning the Department of Defense (DoD) to rescind or withdraw Question and Answer #2 (Q&A 2) from its 2016 interpretative rule for the Military Lending...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

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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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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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MLA Website malfunction

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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

Burr & Forman

Military Lending Act Compliance

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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

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

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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

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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

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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

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

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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

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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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