CUNA joined with other trade organizations last week outlining ways the Department of Defense can improve on unintended negative consequences of the agency’s Military Lending Act (MLA) regulation. The letter urges DOD to issue an interim final rule amending the regulation, creating a single, consistent source of law for servicemembers and their families and the financial institutions that serve them, as well as for regulators and courts.
“Despite almost a year’s experience under the amended regulation, confusion remains about the meaning of several its most important provisions. Additionally, there remain multiple inconsistencies between the regulation and the department’s interpretive rule,” reads the letter, addressed to Secretary of Defense James Mattis. “Together, this confusion and these inconsistencies make it likely that service members and their families might not have full access to safe and responsible credit options.”
The letter also asks DOD to exercise its authority to extend the MLA regulation’s effective date for credit card accounts to Oct. 3, 2018. It is currently set to become effective Oct. 3 of this year.
Included in the letter is language of a potential interim rule, as well as a detailed list of MLA regulation concerns and proposed solutions.
A link to the letter, as well as additional details, can be found on CUNA’s Removing Barriers Blog.
CUNA also joined with the Defense Credit Union Council last month to submit data showing the negative impacts of the MLA rule.
In addition to CUNA, the letter was signed by the American Bankers Association, American Financial Services Association, Association of Military Banks of America, Consumer Bankers Association, Independent Community Bankers of America and the National Association of Federally Insured Credit Unions.