With the compliance deadline for changes to the Department of Defense’s Military Lending Act rules just a week away, ABA is issuing a compliance checklist for bankers and unveiling a new resource webpage combining all ABA resources on the MLA. The MLA amendments — which extend MLA restrictions to cover credit cards, lines of credit, installment loans and deposit advances offered to service members and their dependents — take effect Oct. 3 (though credit cards have a later compliance deadline of October 2017).
The compliance checklist offers bankers a quick guide to major compliance considerations in advance of the rule, which has far-reaching implications for lending to service members and their dependents and a link to additional compliance information that highlights critical areas. ABA’s resource page also includes links to members-only staff analyses, webinars and briefings, news updates, comment letters and other relevant materials to facilitate compliance.
Meanwhile, ABA this afternoon will offer a webinar on surviving MLA compliance, covering the types of loans covered, how and when to identify covered borrowers, how to provide oral disclosures and other topics.
While the final rule was released more than a year ago, it took until August of this year for the Pentagon to issue an interpretive rule clarifying numerous points of confusion and uncertainty that have hindered compliance officers’ ability to prepare. ABA has led the advocacy effort urging DoD to respond to bankers’ concerns and continues to seek guidance and clarification on key issues. For more information, contact ABA’s Nessa Feddis or Rob Rowe.
