DOD publishes guidelines on MLA

The Department of Defense (DOD) published CUNA-requested guidance on changes to the Military Lending Act (MLA) recently. CUNA is currently reviewing the guidance to determine its impact.CUNA has been strongly pushing for this guidance to resolve confusions credit unions have over the changes to the MLA finalized in July 2015 that expand the types of loans covered by the rule.

“Credit unions badly need this guidance so they may continue serving their military members and their families while ensuring they stay in compliance with all rules and regulations,” said CUNA President/CEO Jim Nussle. “This lack of clarity resulted in withdrawal of products and services for military members, as CUNA and the Defense Credit Union Council (DCUC) demonstrated earlier this year. This guidance is a positive step in ensuring servicemembers have access to consumer-friendly financial services.”

CUNA has engaged heavily with the DOD on this matter, most recently in a September meeting with senior DOD officials. CUNA also sent four letters sent since December 2016, and submitted guidance suggestions at DOD’s request.

CUNA and DCUC wrote to the DOD in May sharing research that showed military credit unions were being forced to withdraw products from the market due to uncertainty. CUNA also engaged with regulators and Congress since the MLA changes were finalized, highlighting the many areas of confusion for credit unions. Research showed that almost 60 percent of survey respondents stated that the MLA rule is either “very difficult” (15 percent) or “somewhat difficult” (43 percent) to comply with.

In addition, roughly 60 percent of responding credit unions either “moderately” (32 percent) or “strongly” (27 percent) believe the MLA rule and accompanying MLA guidance is unclear and needs further clarification.