Alert looks at guidance for MLA subjects

Sept. 12, 2016 – A regulatory alert outlining interpretive guidance on subjects related to the 2015 Military Lending Act (MLA) has been issued by NCUA.

According to the alert (#16-RA-06), the guidance clarifies (among other things):

  • Determining a person’s covered borrower status;
  • Exercising a statutory right to take a security interest in a member’s account;
  • Timing and delivering required disclosures; and
  • Identifying fees which can be excluded when calculating the military annual percentage rate for credit card accounts.

“The regulation affects most non-mortgage related consumer credit a lender extends to active duty service members and their dependents,” the alert states. “Credit unions must comply with most of the regulatory changes starting Oct. 3, 2016. Compliance with changes related to credit card accounts begins Oct. 3, 2017.”

NCUA Reg Alert: Interpretive Guidance on MLA Limitations on Terms of Consumer Credit