In dismissing a class action last month alleging violations of the Military Lending Act (“MLA”), a federal district court in Virginia held that the MLA’s two-year statute of limitations is triggered by discovery of the facts...more
In Wood v. Omni Financial of Nevada, Inc., the plaintiffs filed a class action complaint alleging violations of the Military Lending Act (MLA). Specifically, the plaintiffs, two active duty service members who had entered...more
On July 20, 2022, the Federal Trade Commission (“FTC”) and 18 state attorneys general led by New York Attorney General Letitia James announced that they have entered into a settlement with Harris Originals of NY, Inc. and...more
Welcome to Wiley’s update on recent developments and what’s next in consumer protection at the Consumer Financial Protection Bureau (CFPB) and Federal Trade Commission (FTC). In this newsletter, we analyze recent regulatory...more
Last week, Illinois enacted the “Predatory Loan Prevention Act” (SB 1792), which would place a 36% rate cap on nearly all non-bank consumer loans. This act will essentially outlaw small-dollar loans in Illinois and may make...more
On March 23, Illinois Governor Pritzker signed into law SB 1792, which contains the Predatory Loan Prevention Act (the “Act”). The new law became effective immediately upon signing notwithstanding the authority it gives the...more
On March 23, 2021, the Predatory Loan Prevention Act (the “PLPA”) was signed into law by Illinois Governor J.B. Pritzker. The PLPA imposes a 36% military annual percentage rate (“MAPR”) cap on all loans made to Illinois...more
On January 13, 2021, the Illinois legislature overwhelmingly passed SB 1792 (the “Act”), intended to, among other things, overhaul the state’s consumer finance laws. Described prior to enactment as a bill related to “Energy...more
From California to Congress, new legislative proposals are attempting to crack down on interest rates. With interest rates historically set by individual states for particular types of loans, federal caps on interest rates...more
The Department of Defense (DoD) released a new interpretive rule under the Military Lending Act (MLA), building on prior interpretive guidance. What happened - Enacted in 2006, the MLA caps the total charge on covered...more
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
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
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
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
The Department of Defense (DOD) recently finalized amendments to its Military Lending Act (MLA) regulations that impose new compliance obligations on a wide variety of creditors, including issuers of credit cards and...more
The Department of Defense (DoD) recently published its Final Rule amending the Military Lending Act’s (MLA) implementing regulation. The MLA, passed by Congress in 2006, provides active duty service members and their...more