These procedures provide guidance for all examinations covering consumer credit products under the scope of the revised Military Lending Act (MLA) regulation. The MLA, enacted in 2006 and implemented by the Department of Defense (DoD), protects active duty members of the military, their spouses, and their covered dependents from certain lending practices. These practices could pose risks for servicemembers and their families, and could pose a threat to military readiness and affect servicemember retention.
The examination procedures first define key terms, such as the types of consumer credit subject to the regulation, and then guide examiners through reviewing for compliance with the requirements of the regulation:
- Calculation of the Military Annual Percentage Rate (MAPR) (for both open- and closed-end credit)
- Identification of covered borrowers (for creditors electing to use the rule’s optional safe harbors)
- Mandatory loan disclosures
- Other limitations