![]() ![]() The Final Rule expands coverage to include many non-mortgage related consumer credit transactions covered by TILA and Regulation Z, including credit card accounts and payday alternative loans (PALs) federal credit unions make under NCUA’s regulation. To more effectively provide the protections intended to be afforded to Service members and their dependents, DOD amended its regulation primarily to extend the protections of the MLA to a broader range of closed-end and open-end credit products. Initially, the MLA and its implementing regulation only applied to high-cost payday loans, vehicle title loans and refund anticipation loans involving covered borrowers. The Final Rule has different effective dates and compliance dates for specific provisions, as discussed in the Effective Dates section of this document. The purpose of this document is to notify you of the amendments to the MLA regulation so you can take action to ensure compliance with the Final Rule. The Final Rule also contains new provisions about administrative enforcement, penalties and remedies. ![]() 4 It provides safe harbor methods for identifying borrowers covered by the Final Rule, prohibits the use of certain practices, and amends the content of the required disclosures. 2 The Final Rule expands coverage of the current regulation to include many non-mortgage related credit transactions covered by the Truth in Lending Act (TILA), 3 as implemented by Regulation Z. 1 The Final Rule amends the regulation DOD promulgated under the part of the John Warner National Defense Authorization Act for Fiscal Year 2007 called the “Military Lending Act” (MLA). If your credit union provides consumer credit to active duty Service members, their family members or dependents, you likely will have to comply with a final rule the Department of Defense (DOD) has issued establishing new requirements for most non-mortgage related consumer credit transactions (Final Rule). ![]()
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