News & Analysis as of

Military Lending Act Military Service Members Banking Sector

Orrick, Herrington & Sutcliffe LLP

District Court says MLA’s statute of limitations begins upon discovery of facts

The U.S. District Court for the Eastern District of Virginia recently granted an installment lender’s motion to dismiss, ruling that most of the class members’ claims are time-barred by the Military Lending Act’s (MLA)...more

Goodwin

Illinois Imposes 36% MAPR Rate Cap On Consumer Loans; Takes Aim At Fintech-Bank Partnerships And Secondary Market Transactions

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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

Hudson Cook, LLP

Lawfully Serving Servicemembers

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Our country’s military members and their families devote their lives to serving the defense needs of our country, often at great personal sacrifice. As a result, federal and state laws have been crafted to provide these...more

McGuireWoods LLP

A Veterans Day Catch Up on the CFPB’s Surrender of Military Lending Act Supervision

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In light of Veterans Day, there are some recent notable developments regarding the Military Lending Act (MLA) worth discussing. Enacted in 2006, the MLA caps the annual interest rate for an extension of consumer credit to a...more

Nutter McClennen & Fish LLP

Nutter Bank Report, May 2018

Economic Growth, Regulatory Relief, and Consumer Protection Act Signed into Law President Trump signed into law the Economic Growth, Regulatory Relief, and Consumer Protection Act (the “EGRRCPA”) on May 24. The EGRRCPA...more

Ballard Spahr LLP

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

Ballard Spahr LLP

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

Ballard Spahr LLP

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

Ballard Spahr LLP

Cordray’s Letter to President Trump Distorts Impact of Arbitration Rule

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CFPB Director Richard Cordray yesterday sent a letter to President Trump asking him to uphold the Bureau’s arbitration rule even though the Senate recently joined the House in authorizing a repeal of the rule under the...more

Ballard Spahr LLP

Impact on military of CRA override of CFPB arbitration rule continues to be distorted

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Enough is enough! I recognize that reasonable minds can differ with respect to whether the Senate should override the CFPB arbitration rule. However, it is inexcusable when plaintiffs’ lawyers and consumer advocates...more

Ballard Spahr LLP

Protection of servicemembers, Equifax data breach provide mistaken justifications for CFPB arbitration rule

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In a mistaken attempt to justify the CFPB’s arbitration rule, supporters are pointing to the need to protect the rights of military servicemembers and the recent Equifax data breach. On September 20, Democratic Senator Jack...more

Ballard Spahr LLP

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

Ballard Spahr LLP

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

Ballard Spahr LLP

Proposed Bill Would Require Disclosures to Servicemembers Regarding Lower Cost Credit

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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

Ballard Spahr LLP

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

Ballard Spahr LLP

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

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

Ballard Spahr LLP

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

Ballard Spahr LLP

FDIC Releases Revised MLA Exam Procedures and Sets Supervisory Expectations

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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

Ballard Spahr LLP

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

Ballard Spahr LLP

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

Ballard Spahr LLP

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

WilmerHale

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

WilmerHale on

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

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