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NAFCU and six other financial trade associations urged the Defense Department in a letter Thursday to adopt amendments to revised Military Lending Act rules to provide more transparency and consistency for borrowers and the lending industry.

Other signers included the American Bankers Association, CUNA and the Independent Community Bankers of America. They urged the DoD to adopt amendments on an interim basis and to invite public comment on them.

The group's suggestions included:

• the specification that creditors may access accounts by accepting payments from covered borrowers via checks or electronic fund transfers;
• an amendment allowing creditors to provide information to borrowers via mail, telephone or fax; and
• an amendment to allow creditors to impose one-time application fees in the same way they are allowed to charge participation fees to borrowers.

The DoD finalized its MLA rule last July; the regulation took effect Oct. 1, 2015, and compliance is required by this Oct. 3. The department is holding a series of listening sessions for various industry groups so it knows how to proceed with its timeline and what areas of the rule may need further clarification.

The final MLA rule includes several NAFCU-sought concessions and modifications, including to credit union payday alternative loans (PALs) and how a credit union can meet its disclosure requirements under the rule.

Specifically, the final rule allows a credit union to list a toll-free telephone number on all consumer credit applications to satisfy oral disclosure requirements; this relieves the credit union from the burden of checking the MLA database to determine which borrowers need to be given the oral disclosures.