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NAFCU comment letter to DoD re: MLA

WASHINGTON, DC (March 22, 2017) — Good afternoon,

Below please find NAFCU Executive Vice President of Government Affairs and General Counsel Carrie Hunt’s letter to the Department of Defense requesting the department to extend the MLA’s limited exemption for credit card accounts.

In the letter, Hunt wrote, “Credit unions have undertaken considerable efforts to comply with the MLA rule, and they will continue to do so, but the rule’s application to credit card accounts presents many unique challenges.” These challenges suggest that without substantial additional regulatory clarity, many financial institutions will struggle to offer MLA-compliant products.”

“For this reason, we request that the Department immediately exercise the authority it reserved in the MLA rule and extend the exemption for credit card accounts for a full year, until October 3, 2018.”

Hunt thanked the DoD for attending the discussion NAFCU hosted earlier this month on credit union-specific issues and concerns about MLA compliance. NAFCU hosted representatives from the DoD, CFPB, NCUA, credit unions and other industry groups for the discussion. Credit union representatives were able to voice operational concerns and ask questions about specific compliance issues facing the industry.

Hunt also emphasized the difficulties involved in calculating the military annual percent rate (MAPR) for credit card accounts, which will require credit unions to make substantial changes to their existing systems or adopt new systems. She expressed NAFCU’s confidence that with additional time and more regulatory clarity, credit unions will be able to comply with the rule fully.

If you would like more information on this matter or would like to speak about this with a NAFCU expert, please let me know.

Thank you.

Falen Taylor
Communications Coordinator
National Association of Federally-Insured Credit Unions
Phone: 703-842-2235
ftaylor@nafcu.org


About NAFCU

The National Association of Federally-Insured Credit Unions is the only national trade association focusing exclusively on federal issues affecting the nation’s federally-insured credit unions. NAFCU membership is direct and provides credit unions with the best in federal advocacy, education and compliance assistance. For more information on NAFCU, go to www.nafcu.org or @NAFCU on Twitter.

Contacts

Molly Safreed, msafreed@nafcu.org (NAFCU)

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