MLA: A Look Back to Look Forward

The Military Lending Act’s (MLA) Compliance was required by October 3, 2016 for all open-end and closed-end loans not exempt from the final rule, except for credit card accounts which had a compliance date of October 3, 2017.

So what loans are covered by the MLA rule?

The MLA rule initially applied only to Payday Loans, Vehicle Title Loans and Tax Refund Anticipation Loans.

The Amended MLA Final Rule applies to consumer credit –which is credit offered or extended to a covered borrower primarily for personal, family. Or household purposes, and that is: subject to a finance charge; or is payable by a written agreement in more than four installments.

Examples of Closed-End loans that may be covered by the rule:

  • Installment loans,
  • Private Student loans, and
  • Land loans not secured by a dwelling,
  • Small dollar loans including PALs made under NCUA's regulations,
  • Payday loans,
  • Vehicle title loans, and
  • Refund anticipation loans.
  • Examples of Open-End loans that may be covered by the rule:
  • Overdraft Lines-of-credit,
  • Unsecured open-end lines of credit, and
  • Credit Card Accounts.

 

To find out more about MLA, who is exempt and covered borrowers, click here to check out CUNA’s full story.

MLA Resource

CUNA Provides Second-Quarter 2019 Update to The Credit Card MLA Fee Comparison Spreadsheet