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NAFCU Executive Vice President of Government Affairs and General Counsel Carrie Hunt, in a letter to the Defense Department Thursday, emphasized the association's continued concerns about the difficulties of Military Lending Act compliance and urged more guidance.

"Credit unions have undertaken considerable efforts to comply with the MLA Rule, and they will continue to do so," Hunt wrote. "However, the challenges presented by the MLA Rule are substantial, and many financial institutions continue to struggle to determine the parameters of the rule due to ambiguous text and slim guidance."

Hunt highlighted nine areas of concern that require more clarification, including:

• the treatment of co-borrowers;
• the financing of negative equity;
• whether share- and share certificate-secured loans would be prohibited;
• the distinction between loan modifications and refinancing under Regulation Z;
• comparison analysis for "bona fide" fees;
• whether the safe harbor applies to borrowers whose information cannot be found or is incorrect in the DoD database;
• the timing requirement for covered borrower searches;
• what notice provisions would be considered "onerous" or "unreasonable";
• the term "right to legal recourse" as it applies to a waiver.

Hunt also attached a list of frequently asked questions on the MLA to offer background on the issues that credit unions are having trouble with.

Hunt also reiterated NAFCU's call for the DoD to extend the limited exemption for credit cards until Oct. 3, 2018, and she emphasized the importance of fast regulatory relief in that area to prevent unintended negative consequences.