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Military Lending Act

 

Since its implementation in October 2016, your DCUC has been actively involved in several joint meetings with both the National Credit Union Administration (NCUA) and Department of Defense (DOD) seeking further clarification on compliance with the MLA. 

Below you'll find credit union resources for MLA compliance implementation, including the MLA Post-Implementaion Issues webinar and NCUA's "Complying with Recent Changes to the Military Lending Act Regulation" document, to help you get up-to-speed.

 


 

Military Lending Act Post-Implementation Issues Webinar Recording

 

 

The DCUC hosted a FREE webinar titled “Military Lending Act Post-Implementation Issues” in response to several ongoing concerns and issues with the Military Lending Act (MLA) since its implementation last October.

 

 

The following was the basis of our discussion during the FREE webinar:

  • The restriction on imposing a fee or charge on an open-end loan during a billing cycle in which there is no balance;
  • Whether hybrid purchase money/cash out transactions (e.g. auto purchase with negative equity) are entitled to the purchase money exemption under the rule;
  • What constitutes an ancillary product that must be included in the MAPR calculation;
  • Whether a credit union is permitted to exercise a statutory lien right or the right of offset against a covered transaction;
  • What constitutes a “vehicle” for purposes of the regulation;
  • The prohibition against using a remotely created check for repayment of a covered transaction;
  • How a credit union can properly deliver oral disclosures as required by the rule;
  • Determining what makes a credit card fee “bona fide and reasonable” and thus excludable from the MAPR calculation;
  • Whether a credit union, as a holder-in-due-course, is subject to the same claims and/or defenses that a member may raise against an auto dealer who fails to comply with the MLA; and
  • CUNA’s efforts to obtain an exemption for institutions that originate 50 or fewer covered loans.

 

 

NUCA's "Complying with Recent Changes to the Military Lending Act Regulation"

 

The purpose of this document is to notify you of the amendments to the MLA regulation so you can take action to ensure compliance with the Final Rule. 

 

 

 

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