WASHINGTON—CUNA has sent a letter to NCUA sharing concerns the trade association has with the Department of Defense’s Military Lending Act.
Luke Martone, CUNA senior director of advocacy and council, said CUNA has already been in touch with the DoD, NCUA, and the CFPB on the rule, noting that the regulation goes into effect in October and that credit unions still have a lot of questions and need clarification on the act.
In its letter to NCUA, CUNA has raised several specific issues and asking that NCUA provide some clarification. “We hope that there may possibly be some opportunity for delay of the effective date or delay of the examination for the regulation,” Martone explained.
The letter, signed by Chief Compliance Officer Jared Ihrig, states, “The purpose of this letter is to convey issues related to the MLA regulation on which credit unions continue to have questions and seek clarification. These questions continue after the DoD’s August 26 release of compliance guidance as well as the NCUA’s September 12 release of Regulatory Alert 16-RA-04, Guidance on Regulatory Changes Affecting Military Members. While we appreciate the NCUA’s effort to clarify issues not addressed in the DoD’s guidance, we ask the agency to address fully the issues below.”
CUNA outlines five key areas: purchase money loans, ancillary products, statutory liens, safe harbor and definition of “vehicle.”
Meanwhile, in a letter to Deputy Assistant Secretary of Defense for Military Education Diana Banks, NAFCU urged the DoD to delay the effective date of its Military Lending Act rule and provide additional guidance on it.