Second CFPB Consent Order for Military Credit Services, LLC

On Monday, December 19, 2016, in its second action against the company, the CFPB announced a consent order reached with Military Credit Services, LLC (MCS) resulting from alleged improper contractual disclosures. Specifically, the Bureau alleged violations of the Electronic Fund Transfer Act and Truth in Lending Act, and their implementing regulations – E and Z respectively.  According to the consent order, MCS is required to pay $200,000 to the CFPB’s Civil Penalty Fund and ensure its contracts comply with applicable laws.  They are also ordered to hire an independent consultant with specialized experience in consumer finance compliance to conduct an independent review of the company’s issuance and servicing of credit.