20-EF-02: DOD - Military Lending Act Limitations on Terms of Consumer Credit Extended to Servicemembers and Dependents

On February 28, 2020, the Department of Defense (DoD) published an interpretative rule to amend the previous interpretation of the Military Lending Act (MLA). The new interpretation makes two primary changes. First, it rescinds Question and Answer #2 (Q&A #2) as it appears in the DoD’s previous interpretive rule, issued on December 14, 2017 (December 2017 Interpretive Rule), and reverts to a prior interpretation. Second, it adds new Q&A #21 in response to inquiries regarding the use of an Individual Taxpayer Identification Number (ITIN) for determining covered borrower status.

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