On December 14, 2017, the Department of Defense published final interpretive rules (the “2017 Interpretive Rule”) amending previously issued interpretive rules on the Military Lending Act. The 2017 Interpretive Rule amends and replaces three specific questions and answers in the interpretive rules issued by the DOD in August 2016, while also adding a new question…. Read More
Category Archives: Military Issues
Subscribe to Military Issues RSS FeedFinancial Services Report – Spring 2017
Posted in Arbitration, CFPB, Credit Cards, Credit Reports, Electronic Payments, Enforcement Actions, Fair Lending, Foreclosure, Investigations, Military Issues, Mobile Payments, Mortgage, Payday Lending, Preemption, Privacy, Regulatory Developments, State Regulators, Student LendingIn like a lion, out like a lamb—it works for weather; does it work for new administrations? We’ll have to wait and see. We’ll have to wait and see about the length of CFPB Director Richard Cordray’s tenure and the fate of Dodd-Frank, as it appears the Trump administration is focusing on other priorities. So… Read More
Financial Services Report – Winter 2016
Posted in Arbitration, Auto Lending, CFPB, Credit Cards, Disparate Impact, Electronic Payments, Enforcement Actions, Fair Lending, Foreclosure, Military Issues, Mobile Payments, Mortgage, Payday Lending, Preemption, Privacy, Regulatory Developments, State Regulators, UDAAPHope you survived all of those awkward Thanksgiving holiday conversations—amazing how divided people are on whether the court got it right in the PHH case, isn’t it? So on we go into the holiday season, while visions of Dodd-Frank repeal dance in our heads. No long winter’s nap for the CFPB, not with the inauguration… Read More
Financial Services Report – Fall 2016
Posted in Add On Products, Arbitration, CFPB, Credit Cards, Credit Reports, Disparate Impact, Electronic Payments, Enforcement Actions, Fair Lending, Foreclosure, Military Issues, Mobile Payments, Mortgage, Payday Lending, Preemption, Privacy, Regulatory Developments, UDAAPSo much for summer! The weather is cooling, the kids are back to school, and we better not see you wearing white so long after Labor Day! For those of you having a little trouble getting back in the swing of things, we thought we’d lead with just a few of the animals making headlines… Read More
A Closer Look at DOD’s New Guidance on the Military Lending Act Regulations
Posted in Fair Lending, Military Issues, Regulatory DevelopmentsOn August 26, 2016, the DOD issued an interpretive rule (the “Interpretive Rule”) providing guidance on the DOD’s regulations implementing the Military Lending Act. That same day, we published a high-level summary of the Interpretive Rule, noting that the Interpretive Rule aims to clarify certain ambiguities in the DOD’s July 2015 final rule. In this… Read More
Department of Defense Issues New Guidance on Military Lending Act Regulations
Posted in Fair Lending, Military IssuesOn 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… Read More
Financial Services Report – Winter 2015
Posted in Add On Products, Arbitration, Auto Lending, CFPB, Credit Cards, Enforcement Actions, Fair Lending, Indirect Auto Lending, Military Issues, Mobile Payments, Mortgage, Payday Lending, Privacy, Regulatory Developments, Student Lending, UDAAPWe are a full service newsletter, so we offer these can’t-miss Christmas gift ideas for the hard-to-please. Hoverboards are the “It” gift this season, but what about all the poor souls who don’t own one? We’ve devised a remote that lets you seize control from a distance and slam the thing in reverse, toggle forward,… Read More
EVENT: DOD’s Expanded Military Lending Act Rules
Posted in Credit Cards, Events, Fair Lending, Military IssuesThursday, September 3, 2015 2:00 p.m. – 3:00 p.m. EDT Please email cbaker@mofo.com to register for this teleconference. On July 22, 2015, the Department of Defense (DOD) published new rules broadening the scope of current rules implementing the Military Lending Act (MLA). The amended rules significantly expand the scope of the MLA provisions by covering… Read More
Department of Defense Adopts Significant Changes to Its Military Lending Act Regulations
Posted in Credit Cards, Fair Lending, Military IssuesOn July 22, 2015, the Department of Defense (DOD) published 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 installment loans and other closed-end credit products and credit cards… Read More
DOD Adopts Sweeping Changes to Rules Implementing Military Lending Act Provisions
Posted in Credit Cards, Fair Lending, Military IssuesOn 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,… Read More
CFPB Increasingly Aiming “Abusiveness” Claims at Servicemember Products and Services
Posted in Auto Lending, CFPB, Disparate Impact, Enforcement Actions, Military IssuesAre servicemembers more financially vulnerable than the civilians they protect? Recent enforcement actions suggest that, in the CFPB’s view, they are. While the Servicemembers Civil Relief Act (SCRA) provides more financial protections to servicemembers than civilian consumers have, the Bureau has also begun to use the CFPA to assert “abusive” claims in cases involving alleged… Read More
CFPB Weighs in on Department of Defense Military Lending Act Proposed Rule
Posted in CFPB, Military IssuesOn December 29, 2014, the Consumer Financial Protection Bureau (CFPB) released a report, entitled “The Extension of High-Cost Credit to Servicemembers and Their Families” (“Report”). According to the CFPB, the Report provides a “snapshot” of the market for “high-cost credit products” that are not currently covered by the Military Lending Act (MLA). The CFPB released… Read More
The SCRA – Collections, Compliance and Enforcement in the Age of the Servicemembers Civil Relief Act
Posted in Enforcement Actions, Events, Military IssuesUpholding the rights of the military under the Servicemembers Civil Relief Act (SCRA) is an important way to honor their service. The SCRA provides servicemembers a number of unique protections and benefits, and noncompliance carries potentially enormous legal and reputational risks for your business. Join LexisNexis and Morrison & Foerster for a free webinar: The… Read More