ABA today hosted a meeting with representatives from the Department of Defense, trade associations and financial institutions to discuss ongoing issues related to the Military Lending Act amendments that took effect in October. Attendees addressed several areas that still need clarity, including the exemption for purchase money loans and whether covered borrowers may obtain loans secured by a bank account.
Also raised at the meeting were issues related to credit cards, which have a separate compliance date of Oct. 3, 2017. A main point of discussion was how to determine whether credit card fees are “reasonable” and thus excludable from the military APR. Participants also discussed ways to improve the systems used to determine military status through credit reporting agencies, the DoD’s MLA website and direct access to the MLA database.
ABA and the industry will continue to engage with DoD to clarify and improve the MLA regulation. To help bankers comply with the MLA rules and amendments, ABA offers a suite of resources on its dedicated MLA webpage. For more information, contact ABA’s Nessa Feddis or Rob Rowe.