By Brandy Bruyere
Tick, tock… The countdown to the compliance deadline for the Department of Defense (DoD) Military Lending Act (MLA) final rule is upon us.
With just a few months to meet the Oct. 3 deadline, NAFCU has been working tirelessly in its advocacy and regulatory compliance efforts to help credit unions get up to speed on this complex rule.
Indeed, the devil is in the details with the new MLA rule. It significantly expands the variety of products that must now adhere to MLA. Many credit unions whose products were not covered under previous MLA requirements must develop rigorous MLA compliance policies and procedures before the majority of the changes are implemented on Oct. 3.
To address the rule’s broad scope and help ease the compliance process for member credit unions, NAFCU and its regulatory compliance team have created a plethora of resources – NAFCU’s Final Regulation report, a webcast and numerous compliance blog posts – to assist credit unions in meeting their growing MLA regulatory compliance responsibilities. For example, NAFCU’s Military Lending Act Guide is an invaluable 23-page goldmine of information that takes a close look into the key areas of the MLA final rule.
NAFCU’s other MLA compliance resources also include a scope-and-applicability chart and a list of frequently asked questions.
Other Calls For Improvements
Additionally, NAFCU has maintained a steady drumbeat in advancing credit unions’ concerns before DoD and other regulators to secure much-needed improvements including clear compliance guidance in the final rule.
- In December 2015, NAFCU Director of Regulatory Affairs Alexander Monterrubio addressed the consumer impact of the latest MLA changes and new DoD policies with representatives from the Consumer Financial Protection Bureau (CFPB) and the Georgia Attorney General’s office, at the Consumer Federation of America’s Financial Services Conference in Washington.
- In February 2016, NAFCU participated in a joint trades meeting with the Defense Manpower Data Center (DMDC) on the MLA database.
- Another meeting followed in March, where NAFCU and several NAFCU-member credit unions underscored for DoD representatives the credit union industry’s MLA compliance concerns. NAFCU was the only trade association to bring member credit unions to participate in the discussions.
- In April, NAFCU joined six other financial trade associations in a letter to the DoD providing an outline of specific amendments to the MLA final rule that would provide more transparency and clarity to covered borrowers and the lending industry.
- NAFCU has met with NCUA on several occasions to discuss credit union concerns regarding the MLA final rule.
Going forward, we continue to press DoD for clarity and are advocating to have the deadline for credit cards extended from Oct. 3 2017 to Oct. 3, 2018. Two other critical measures NAFCU-sought in the MLA final rule were included: the first allows a credit union to list a toll-free telephone number on all consumer credit applications to satisfy oral disclosure requirements, and the second makes a concession to credit union payday alternative loans (PALs). NAFCU has been at the vanguard of the MLA rule and as the deadline grows nearer, we will keep fighting for you and be your ally in successfully navigating the MLA rule.
Brandy Bruyere is Director of Regulatory Compliance with NAFCU. For info: www.nafcu.org.