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NASCUS hosted a teleconference February 4 between the Department of Defense (DoD) and state regulators to continue the development of communication and implementation tools to enforce consumer lending regulations for military.
As discussed previously, the DoD and state regulators are developing Memos of Understanding (MOU) between state agencies and the Department to facilitate the information sharing critical to enforcement. The purpose of the MOU is to enhance communications and the exchange of information for prompt and effective resolution of consumer complaints and alleged violation of 32 CFR Part 232, the regulation implementing the consumer lending provisions of the Defense Authorization Act of 2007.
Attendees on the call included state regulators representing NASCUS, the Conference of State Bank Supervisors (CSBS) and the National Association of Consumer Credit Administrators (NACCA). The call provided participants the opportunity to comment on the MOU. Legal counsel at the DoD will review the document next and the organizations will make it available for regulators for review before it is discussed with individual state agencies and the DoD.
Participants on the call also reviewed DoD’s forthcoming response to the Senate for feedback on the treatment of additional financial products that could negatively affect military personnel. NASCUS is responding to the DoD’s request for comments. The DoD assured state regulators on the teleconference that the inquiry was not a prelude to additional regulations, but a response to the Senate’s inquiry. To view the Federal Register notice, click here.
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