In July 2015, the Department of Defense (DoD) released its final rule amending regulations under the Military Lending Act (MLA). The new rule vastly expands the number and types of products that are subject to the MLA. Credit unions that weren't covered before must now develop rigorous MLA compliance policies and procedures before the majority of the changes must be implemented, starting October 3, 2016.
Below you'll find credit union resources for MLA compliance implementation, including compliance guide, final rule summary, insightful blog posts, articles and webcasts, to help you get up-to-speed.
Resources marked by * are member-only. If you are not a NAFCU member, learn more about membership.
Compliance Deadline: October 3, 2016
(Credit card compliance deadline is October 3, 2017)
MLA Second Interpretative Rule Redline*
Guides & Tools
- Complete MLA Compliance Guide*
Updated May 2018 with more details on the DoD's amended interpretive rule from December 2017! A helpful compliance reference for credit unions that addresses many key areas of the DoD's MLA rule including credit cards, security interests and calculating the MAPR. Details include discussions on the effect of financing add-on products, share-secured loans and more.
- MLA Scope & Applicability Chart*
A handy resource detailing the background, scope and exemptions for the new MLA requirements.
- Frequently Asked Questions on the Amended MLA Interpretative Rule*
- Military Lending Act: Implementation Frequently Asked Questions*
- NCUA's Military Lending Act Examination Approach
- Compliance Central: NCUA's Military Lending Act Examination Approach
NAFCU Compliance Blog Posts
- MLA FAQ – MAPR on Periodic Statements (November 15, 2017)
- MLA Credit Card FAQ – Bona Fide and Reasonable Fees Outside the Safe Harbor (October 2, 2017)
- MLA and Prescreened Offers of Credit (September 11, 2017)
- Another MLA FAQ: Is the Credit Card Rule Retroactive? (August 25, 2017)
- MLA and the MAPR for Credit Cards – The Tedious Task of Researching Call Reports and Card Agreements (May 12, 2017)
- MLA and Credit Cards – Late Fees, Returned Payment Fees and More; Prepaids Rule Delayed (April 24, 2017)
- MLA: Credit Cards and the Bona Fide Fee Exemption (March 17, 2017)
- MLA Compliance – Covered Borrower False Positives/Negatives, Historic Lookback Prohibition; The Downside of Compromise (February 27, 2017)
- MLA Compliance Deadline Today – CFPB Updates Examination Procedures to Address MLA (October 3, 2016)
- DoD's Interpretive Guidance on MLA: Part III – Definition of "Vehicle" (September 9, 2016)
- DoD's Interpretive Guidance on MLA: Part II – Oral Disclosures Can Be Generic (August 31, 2016)
- U.S. Department of Defense Issues Interpretive Guidance on MLA – Share Secured Loans and Statutory Liens Revisited (August 29, 2016)
- Searching for the Missing MLA Definitions (June 6, 2016)
- Defining "Credit-Related Ancillary Products" under the U.S. Department of Defense's MLA Rule (May 25, 2016)
- Treatment of Refinance Transactions under the MLA Rule (May 2, 2016)
- More MLA FAQs (January 25, 2016)
- Military Lending Act – Some FAQs (December 9, 2015)
Visit the NAFCU Compliance Blog for more MLA compliance blog posts.
Department of Defense MLA Chart