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

Elizabeth Eurgubian

Deputy Chief Advocacy Officer & Senior Counsel Credit Union National Association

Celia Winslow

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

Alexander Monterrubio

Director of Regulatory Affairs

National Association of Federally-Insured Credit Unions

David Pommerehn

Vice President & Associate Senior Counsel

Consumer Bankers Association



cc:  The Honorable Richard Cordray, Director, Consumer Financial Protection Bureau3