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MoFo Reenforcement The Enforcement Blog

Department of Defense Issues New Guidance on Military Lending Act Regulations

Posted in Fair Lending, Military Issues

On August 26, 2016, the Department of Defense (DOD) issued an interpretive rule providing guidance on the DOD’s regulations implementing the Military Lending Act (MLA). Specifically, the interpretive rule aims to clarify certain ambiguities in the DOD’s July 2015 final rule, which significantly expanded the scope of the MLA to cover new types of creditors and new credit products. Presented in a series of questions and answers—19 in total—the interpretive rule by no means resolves all ambiguities present in the July 2015 final rule. The interpretive rule does, however, provide much needed clarity on a handful of issues that are critical to creditors’ compliance with the MLA. In this alert, we offer a high-level summary of some of the most significant issues addressed by the interpretive rule.

Read our client alert.