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MLA Guidance Issued – Credit Unions Ask for Delay in Implementation

The Heartland Credit Union Association (HCUA) Compliance team is focused on the Department of Defense (DOD) Military Lending Act (MLA) as Kansas and Missouri credit unions – along with credit unions across the country - work to comply with the rule by the effective date of October 3, 2016. The DOD published its long-awaited follow-up guidance on August 26. 

The DOD’s 24-page guidance is provided in a question-and-answer format, and many of the issues included were raised by the credit union industry. While the guidance includes some key clarifications, there are still many unanswered questions.

Following the guidance release, the Credit Union National Association (CUNA) has requested a six-month delay in implementation from the DOD. If a delay in effective date is not granted, the agency was asked to adopt a six-month safe harbor for lenders who are working to comply but are unable to do so by October 3. 

For now, the MLA Final Rule effective date of October 3, 2016 remains unchanged. HCUA Compliance will keep member credit unions posted on any developments, delays and/or additional guidelines as available.

If you have questions, please contact HCUA Compliance at 800.446.3620 or 314.542.1382.