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ARTICLE · 03 FEBRUARY 2015

Banking Industry Protests CFPB Military Lending Study

Troutman Pepper Locke LLP
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On January 16, the American Bankers Association (ABA) issued a letter opposing a proposal offered by the Department of Defense to amend the regulations that implement the Military Lending Act.

United StatesFinance and Banking
Brendan Connors
Brendan Connors
William Hurd
William Hurd
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On January 16, the American Bankers Association (ABA) issued a letter opposing a proposal offered by the Department of Defense to amend the regulations that implement the Military Lending Act.  Although the ABA had already joined other trade associations in a December 18 joint comment letter criticizing this proposal, the organization submitted this latest letter in response to a December 29 study supporting the DOD proposal published by the Consumer Financial Protection Bureau entitled "The Extension of High-Cost Credit to Servicemembers and Their Families."

As we reported in a post on December 31, this CFPB study highlighted the various ways lending institutions have allegedly been exploiting loopholes in the Military Lending Act to exact inflated fees from military personnel.  The study intentionally bolstered the referenced DOD proposal to broaden the scope of the Act to cover a larger swath of credit instruments, including deposit advance products (DAPs) as

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