Defense Department and FHFA Extend Comment Periods

November 27, 2014 Comment periods on two proposed federal regulations have been extended. Both regulations affect some credit unions.

The Department of Defense (DoD) has extend the comment period for its proposed amendments to its regulation implementing the Military Lending Act (MLA). Comments are now due December 26, 2014. DoD is proposing, among other things, to extend the MLA’s 36% interest rate cap (MAPR) on payday and vehicle title loans to a wide variety of open and closed end credit products for military personnel and their dependents. DoD also proposes replacing the MLA’s current disclosure based process for identifying covered borrowers with a database driven process. A complete NASCUS summary of the proposal is available here.

The Federal Housing Finance Agency (FHFA) has extended the comment period on its proposal to amend its regulations governing Federal Home Loan Bank. Comments are now due to the FHFA by January 12, 2015. FHFA’s proposal would extend application requirements for members to hold 1%, and in some cases 10%, of their assets in residential mortgage loans to an ongoing membership requirement. FHFA also proposes excluding “captive insurers” from membership. A NASCUS summary of the proposal is available here.


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