The federal banking agencies today issued updated interagency examination procedures for the amendments to the Military Lending Act rule, which extend MLA restrictions to cover credit cards, lines of credit, installment loans and deposit advances offered to service members and their dependents. The new restrictions are now in effect (with a later compliance date for credit cards of Oct. 3, 2017).
The revised examination procedures are based on those developed jointly by other banking agencies. Early MLA compliance examinations will focus on financial institutions’ compliance management systems and overall efforts to comply, including implementation plans, actions to update policies and procedures, staff training and handling of early implementation hurdles. The OCC said it will incorporate the revised procedures in its Comptroller’s Handbook as a supplement to the interagency procedures. For more information, visit ABA’s MLA resource page or contact Nessa Feddis or Rob Rowe.