WASHINGTON—NAFCU, CUNA and four other financial services trade associations are urging the Federal Financial Institutions Examination Council to delay compliance examinations of the Department of Defense’s Military Lending Act changes until March 3, 2017 – giving the industry six months to test its systems.
In a joint letter to the FFIEC, the trades pointed out that because of the significant changes to the types of accounts now covered under the MLA, and the number of unresolved issues that still exist within the rule, financial institutions should be allotted at least six months to test their compliance systems after the rule’s compliance date of Oct. 3.
“We believe that this approach is not only fair and practical, but will help to ensure that military personnel, their spouses and dependents continue to have access to depository institution credit products they need and value,” stated the letter, sent to CFPB Director Richard Cordray and NCUA Board Chairman Rick Metsger, along with all the other members of the FFIEC.
The letter also noted that the industry still has several lingering concerns regarding implementation of the rule. NAFCU said it has met with DoD on three separate occasions this year and sent a letter advocating for an immediate extension of the credit card implementation date, which is currently set for Oct. 3, 2017.
The Independent Community Bankers of America, the ABA, the Consumer Bankers Association, and the Association of Community Banks of America also signed the letter.
In June, NAFCU updated its collection of compliance resources related to the MLA. The collection includes information on delivering oral disclosures, calculating the Military Annual Percentage Rate for open-end credit and how the MLA applies to loans for purchases of land, boats and RVs. NAFCU said its compliance guide is currently undergoing further updates due to the release last week of DoD’s interpretative guidance.