WASHINGTON—Continuing its efforts to get some clarification on the Department of Defense’s Military Lending Act (MLA) regulation, CUNA has sent a letter to the DoD urging answers for several outstanding questions.
The letter returns to several topics the trade association raised in a September letter to NCUA, and reflects issues on which CUNA said it continues to receive inquiries.
The changes to the MLA establish limitations on terms of consumer credit extended to servicemembers, and they became effective in October. CUNA said it has had a number of meetings with both the DoD and NCUA to share questions brought by credit unions as they work to comply with the regulation.
CUNA believes the following issues need clarifications:
- Purchase money loans;
- Ancillary products;
- Statutory liens;
- Share-secured loans;
- The term “vehicle;”
- Credit card fees; and
- Oral disclosures.
CUNA also urged the DoD to exempt certain credit unions that make few covered loans, and suggested that credit unions that made fewer than 50 covered loans in the previous calendar year should be exempt from MLA compliance.