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FOR IMMEDIATE RELEASE | January 31, 2018

NAFCU and DCUC Take MLA Compliance Challenges to Defense Dept

FOR IMMEDIATE RELEASE

Washington (Jan. 31, 2018) -- National Association of Federally-Insured Credit Unions (NAFCU) President and CEO Dan Berger andDefense Credit Union Council (DCUC) President and CEO Anthony Hernandez today wroteto the Department of Defense(DoD) detailing the compliance challenges associated with the DoD's explanation ofguaranteedacceptanceprotection (GAP) insurance housed within the Military LendingAct (MLA) rule.This insurance is addressed in question-and-answer No. 2 from the DoD's 2016 interpretive rule amendmentsreleased last month.

The groups asked that DoD rescind the question from its interpretive rule and the subsequent amendments due to the confusion it has created for credit unions and their third-party vendors.

"Credit unions, especially those with fields of membership closely tied to the service branches and/or military facilities, have a strong commitment to ensuring servicemembers have access to high-quality financial products and services," Berger and Hernandez wrote. "However, the compliance challenges presented by the MLA Rule are substantial and many credit unions continue to grapple with the parameters of the rule due to ambiguous regulatory text and muddled guidance.

Since the MLA rule was enacted in 2015, credit unions have faced numerous challenges, including finding ways to better understand the rules interpretive language and ensuring that third-party lenders are compliant.

The letter also reiterates credit unions' commitment to protecting servicemembers and their families from financial exploitation, and the substantial efforts the industry has already undertaken to comply with the MLA rule.

Forfulltext of the letter, please click here.

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The National Association of Federally-Insured Credit Unions is the only national trade association focusing exclusively on federal issues affecting the nation's federally-insured credit unions. NAFCU membership is direct and provides credit unions with the best in federal advocacy, education and compliance assistance. For more information on NAFCU, go towww.nafcu.orgor@NAFCUon Twitter.

Jacqueline Ramsay
jramsay@nafcu.org