Bank examiner handbook incorporates Military Lending Act consumer credit rule changes, DoD interpretations

A new “Military Lending Act” (MLA) booklet was issued Friday as part of the Consumer Compliance series of the Comptroller’s Handbook, which is used by Office of the Comptroller of the Currency (OCC) examiners to assess banks’ MLA compliance. MLA applies to consumer credit offered to military service members and their dependents. The new booklet reflects Department of Defense (DoD) amendments affecting closed-end and most open-end consumer credit consummated or established on or after Oct. 3, 2016, and to credit card accounts established on or after Oct. 3, 2017, that were published in 2015, plus related DoD interpretations published in 2016 and 2017.

This booklet replaces and rescinds the “Limitations on Terms of Consumer Credit Extended to Servicemembers and Dependents” procedures that were found in the “Other Consumer Protection Laws and Regulations” booklet of the Comptroller’s Handbook. It incorporates the interagency MLA examination procedures developed by the Federal Financial Institutions Examination Council (FFIEC) Task Force on Consumer Compliance (2016 interagency MLA examination procedures) and rescinds OCC Bulletin 2016-33, “Military Lending Act: Revised Interagency Examination Procedures Regarding Limitations on Terms of Consumer Credit Extended to Service Members and Dependents.” Bulletin 2016-33 accompanied the 2016 interagency MLA examination procedures.

OCC Bulletin 2018-11

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