On July 21, 2015, the Department of Defense (DOD) adopted sweeping changes to its rules that implement the Military Lending Act (MLA). The amended rules significantly expand the scope of the MLA provisions by covering both new types of creditors and new credit products, including credit cards. The new rule becomes effective on October 1, 2015, with compliance required by October 3, 2016. However, compliance with the rules for credit cards is delayed until October 3, 2017, unless extended for an additional year, until October 3, 2018.
There are many complexities, exceptions, special provisions and nuances associated with the final rule. This alert provides a high-level summary of the main provisions. A detailed analysis is forthcoming.
Read our client alert.