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Joint Trades Letter DoD re MLA
June 21, 2017
The Honorable James Mattis
Secretary of Defense
1000 Defense Pentagon
Washington, DC 20301-1000
Dear Mr. Secretary,
As we approach the first anniversary of the implementation of the Department of Defense’s amended Military Lending Act (MLA) Regulation, the Financial Trade Associations – the American Bankers Association, the American Financial Services Association, the Association of Military Banks of America, the Consumer Bankers Association, the Credit Union National Association, the Independent Community Bankers of America, and the National Association of Federally-Insured Credit Unions – offer our thanks for your willingness to work with us to ensure the MLA works for both the military community and the financial organizations that serve it. For example, the Department’s Interpretive Rule, released last August, addressed many of our concerns and thereby avoided unintended adverse consequences military families would otherwise have suffered.
Despite almost a year’s experience under the amended Regulation, confusion remains about the meaning of several its most important provisions. Additionally, there remain multiple inconsistencies between the Regulation and the Department’s Interpretive Rule. Together, this confusion and these inconsistencies make it likely that service members and their families might not have full access to safe and responsible credit options.
We share a desire to ensure responsible credit remains available to all military members and families and believe the Department can best achieve that goal by issuing an interim final rule for public comment that eliminates confusion and inconsistency in this area. The attached letter explains these issues in detail and offers solutions and language for an interim final rule. Because a considerable number of these issues arise in the credit card arena, we also respectfully urge the Department to exercise its authority to extend the MLA Regulation’s effective date for credit card accounts to 3 October 2018. These two steps are critical to the financial industry’s smooth and effective implementation of the MLA regulations strict standards. They have the added benefit of advancing President Trump’s mandate to reduce the number and burden of administrative regulations.
The Financial Trade Associations thank the Department again for its collaborative spirit and the work we have done together for the benefit of our military members and their families. We look forward to continuing that work to ensure the financial products and services available to them are equivalent in quality and quantity to those available to the general public.
Nessa A. Feddis
Senior Vice President & Deputy Chief Counsel American Bankers Association
Deputy Chief Advocacy Officer & Senior Counsel Credit Union National Association
Director, Legal & Regulatory Affairs American Financial Services Association
Viveca Y. Ware
Group Executive Vice President, Regulatory Policy Independent Community Bankers of America
Steven J. Lepper
Major General, USAF (Ret.) President & CEO
Association of Military Banks of America
Director of Regulatory Affairs
National Association of Federally-Insured Credit Unions
Vice President & Associate Senior Counsel
Consumer Bankers Association
cc: The Honorable Richard Cordray, Director, Consumer Financial Protection Bureau3