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NCUA said Tuesday that its examiners will accept credit unions' "reasonable and good faith efforts" to comply with the Military Lending Act rules that went into effect this week, according to Letter to Credit Unions 16-CU-07.

NAFCU Executive Vice President of Government Affairs and General Counsel Carrie Hunt said the association appreciates NCUA's consideration of good faith efforts, but she noted NAFCU still has concerns about the rules. NAFCU has noted ambiguities resulting from the Defense Department's recent interpretive guidance on the rules, particularly relating to hybrid purchase money loans and share-secured loans that some credit unions think could lead to litigation risk.

NAFCU has also urged the Federal Financial Institutions Examination Council to delay compliance examinations of the rules until March 3, 2017 – giving the industry six months to test its systems.

In its letter, NCUA said credit unions must also guard against third-party liability.

"Credit unions should understand that NCUA's acceptance of good faith efforts for supervision purposes does not shield a credit union from the third-party liability that can arise under the MLA," NCUA wrote. "Your principal and most immediate goal should be to ensure servicemembers and other covered borrowers are receiving the consumer protections the MLA provides."

The new MLA rule expands the number of products covered by MLA, meaning credit unions will have to revamp how they identify covered borrowers and services.

NAFCU's extensive collection of MLA compliance resources, including the MLA Compliance Guide, is available online.