The CFPB issued examination procedures for the amendments to the Military Lending Act rule taking effect as soon as today. The procedures are based on those developed jointly by other banking agencies.
The bureau’s early MLA compliance examinations will focus on financial institutions’ compliance management systems and overall efforts to comply, including implementation plans, actions to update policies and procedures, staff training and handling of early implementation hurdles.
The MLA amendments -- which extend MLA restrictions to cover credit cards, lines of credit, installment loans and deposit advances offered to service members and their dependents -- take effect today (though credit cards have a later compliance deadline of October 2017).
View the exam procedures.