The Department of Defense (DOD) has denied a request from CUNA and other organizations to delay the effective date of credit card provisions in the Military Lending Act (MLA), changes that are effective Tuesday. CUNA wrote to the DOD in June asking for the delay due to lack of guidance, which they said creates compliance challenges that could result in less availability of credit to servicemembers and families.
DOD finalized changes to the MLA in July 2015, expanding the types of loans covered by the rule and placing limitations on terms of consumer credit extended to servicemembers and their families.
The DOD’s letter did confirm that it is “presently working” on clarifying guidance highlighted in the June letter through an interpretive rule amendment. More details can be found on CUNA’s Removing Barriers Blog.
CUNA outlined numerous concerns with the regulation in letters to DOD, NCUA and Congress, and met last month with senior DOD officials to reiterate those concerns.
CUNA launched an interactive spreadsheet for members last week to help credit unions calculate whether credit card fees are “bona fide and reasonable” under the MLA.