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Category Archives: Military Issues

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MLA Website malfunction

Posted in Military Issues

According to an announcement posted on the Military Lending Act (“MLA”) Website, “[b]etween February 9, 2017 and February 15, 2017 there was a problem with MLA Multiple Record Requests that prevented 149 request files from processing.” The Defense Manpower Data Center advises any creditor who, during the time period in question, submitted a Multiple Record… More >

CFPB settles with military financing company for alleged TILA/EFTA disclosure violations

Posted in CFPB Enforcement, Military Issues

The CFPB announced that it has entered into a consent order with Military Credit Services, LLC, a company providing revolving credit to military consumers, to settle allegations that the company’s open-end credit agreements violated the Truth in Lending Act and the Electronic Fund Transfer Act.  MCS had entered into a consent order with the CFPB… More >

GAO report highlights gap in SCRA oversight for private student loans; encourages CFPB to seek additional statutory authority

Posted in Military Issues

On November 18, the GAO released a report examining issues related to implementation of the Servicemembers Civil Relief Act (SCRA) interest rate cap for student loans. The Senate Committee on Homeland Security and Governmental Affairs requested the report in response to indications that servicemembers with student loans who are eligible for an SCRA rate reduction… More >

CFPB to participate in interagency MLA webinar

Posted in Military Issues

On December 1, 2016, the  FDIC will co-host an interagency webinar that will focus on Military Lending Act regulations and the Department of Defense’s recently-released interpretive rule. In addition to a CFPB representative, the other webinar participants will consist of representatives of the FDIC, OCC, and Federal Reserve.    

As part of joint initiative with the CFPB, FTC launches updated, mobile-friendly Military Consumer website

Posted in Military Issues

Yesterday, the FTC announced the launch of a redesigned Military Consumer website as part of its joint initiative with the DoD, CFPB and others. is a financial readiness website designed to help servicemembers and their families navigate consumer decisions and protect against fraud. The website also provides tools for personal financial managers, counselors, and… More >

CFPB issues report on servicemember complaints

Posted in Military Issues, Mortgages

A new CFPB report, “A snapshot of servicemember complaints,” focuses on issues related to VA mortgage refinancing. The report indicates that as of November 1, 2016, the CFPB had received over 12,500 mortgage complaints from servicemembers, veterans, and their dependents.  The CFPB determined based on a key word search of complaint narratives that approximately 18%… More >

FDIC Releases Revised MLA Exam Procedures and Sets Supervisory Expectations

Posted in Military Issues

On October 17, the FDIC released revised interagency Military Lending Act (MLA) examination procedures for use in connection with consumer credit transactions occurring on or after October 3, 2016. The revised procedures reflect the Department of Defense’s July 2015 final rule and August 2016 interpretive rule and appear consistent with those released by the CFPB… More >

CFPB enters into consent order with credit union

Posted in CFPB Enforcement, Military Issues

The CFPB announced that it has entered into a consent order with Navy Federal Credit Union to settle allegations that the credit union engaged in unfair and deceptive collection practices in violation of the Consumer Financial Protection Act.  The consent order, which appears to be the CFPB’s first consent order involving a credit union, requires Navy… More >

SCRA website malfunctioning

Posted in Military Issues

According to an announcement posted on the Servicemembers Civil Relief Act Website, “[a] bug in the SCRA website is causing the site to give false negatives for some National Guard members whose service should be positively reported by the site.”  The DMDC advises that it is working to resolve the issue, but that a fix will… More >

DoD issues MLA interpretive rule; Ballard to hold Sept. 20 webinar

Posted in Military Issues

The Department of Defense (DoD) has issued an interpretive rule to assist the industry in complying with its July 2015 final rule amending the Military Lending Act’s implementing regulation.  The much-anticipated guidance was published in the Federal Register on August 26, 2016, just over one month before the final rule’s October 3 compliance deadline for… More >

Trade groups seek de facto extension of compliance date for Military Lending Act final rule

Posted in Military Issues

The American Bankers Association, joined by six other prominent industry trade groups, is seeking to postpone by six months the date on which examiners will begin transactional testing of depository institutions for compliance with the Military Lending Act (MLA) final rule adopted by the Department of Defense (DoD) in July 2015 that dramatically expanded the scope… More >

Holly Petraeus to retire from CFPB

Posted in Military Issues

According to Politico, Holly Petraeus, Assistant Director of the CFPB’s Office of Servicemember Affairs, will be retiring from the CFPB. During her tenure at the CFPB, the protection of military servicemembers and their families has been a focus of CFPB supervisory and enforcement activity.  Among other things, Ms. Petraeus was a vociferous advocate for the… More >

CFPB issues fourth annual report on servicemember complaints

Posted in Military Issues

The CFPB’s Office of Servicemember Affairs released its fourth annual report highlighting complaints submitted in 2015 by servicemembers, veterans, and their families. The report states that in 2015, the CFPB received approximately 19,200 complaints from members of the military community.  (Total complaints received by the CFPB in 2015 were approximately 271,600.)  Approximately 71 percent of… More >

CFPB issues snapshot of servicemember complaints

Posted in Military Issues, Payday Lending

The CFPB has issued a new “snapshot of servicemember complaints.”  The report states that as of November 2015, the CFPB had received about 2,500 complaints from servicemembers, veterans and their dependents about high-cost consumer credit.  These complaints were submitted under two complaint categories: the “payday loan” category or under the “debt collection” category with “payday… More >

FTC and VA enter into agreement for investigating educational institutions

Posted in FTC, Military Issues

The Federal Trade Commission and the Department of Veterans Affairs have signed a “Memorandum of Agreement” (MOA) “to provide mutual assistance in the oversight and enforcement of laws pertaining to advertising, sales, and enrollment practices of institutions of higher learning and other establishments that offer training for military education benefits recipients.” Federal law (38 U.S.C…. More >

CFPB Speaks Out on Behalf of Disabled Veterans

Posted in Military Issues

In a blog post on the CFPB website, the CFPB advocated on behalf of veterans with service-connected disabilities, who face obstacles when transitioning back to civilian life and working to become financially secure. The CFPB emphasized that individuals with disabilities have the right to fair treatment in the financial marketplace and access to tools that… More >

Defense Department dramatically expands scope of Military Lending Act

Posted in Military Issues

The Department of Defense (DoD) dramatically expanded the scope of the Military Lending Act (MLA) on July 22, 2015, publishing its Final Rule amending the MLA’s implementing regulation.  The DoD consulted with the CFPB in developing the Final Rule, and the CFPB actively supported the DoD’s plans to expand MLA coverage. MLA coverage was previously… More >

CFPB sends warning letters on military allotment practices

Posted in Military Issues

The CFPB announced that it sent warning letters this month to several companies that sell retail goods to military servicemembers regarding their acceptance of payments made through military allotments.  The military discretionary allotment system allows servicemembers to automatically direct a portion of their paychecks to financial institutions or others of their choosing.  Effective January 1, 2015,… More >

Director Cordray appears before Senate Banking Committee

Posted in Arbitration, CFPB General, Military Issues, Mortgages, Payday Lending

On Wednesday, July 15, CFPB Director Richard Cordray appeared before the Senate Committee on Banking, Housing, & Urban Affairs to answer questions regarding the Bureau’s Semi-Annual Report to Congress and the President, which it published on June 15, 2015. Dir. Cordray observed that during the six month period covered by the report, from October 2014 through… More >

CFPB issues new report on servicemember student loans

Posted in Military Issues, Student Loans

A new CFPB report entitled “Overseas & Underserved: Student Loan Servicing and the Cost to Our Men and Women in Uniform” contains the CFPB’s findings regarding student loan servicing problems faced by servicemembers.  According to the CFPB, it has handled more than 1,300 complaints from military borrowers relating to the servicing or collection of student… More >

Proposed MLA expansion cleared to move forward

Posted in Military Issues

Yesterday, the House Armed Services Committee removed language from the draft Fiscal Year 2016 National Defense Authorization Act that would have delayed the finalization of rules proposed by the Department of Defense that would expand the types of credit subject to the Military Lending Act.  As we have previously discussed, the proposal faces strong criticism… More >

CFPB issues third servicemembers complaints report and suggests practices for handling servicemember accounts

Posted in Military Issues

The CFPB has issued its third snapshot of complaints received from servicemembers, veterans and their families (“servicemember complaints”).  The report covers complaints received from July 21, 2011 through December 31, 2014.  In 2014, the CFPB received more than 17,000 complaints from such individuals (out of a total of approximately 29,500 complaints received over the entire… More >

Proposed MLA expansion in limbo

Posted in Military Issues

Despite the CFPB’s efforts to build support for the Department of Defense’s proposal to significantly expand Military Loan Act coverage, it now appears that the proposal may be put on hold. The DoD proposal would revise the scope of “consumer credit” subject to MLA restrictions to include, regardless of term or amount, all unsecured open-end… More >