DoD Issues FAQs on Military Lending Act (8/25/16)
DoD’s expected "interpretive rule" to its Military Lending Act Regulation is now available. The interpretive rule provides some positive guidance that ABA had sought after the rule was published last July, including clarifications that banks may continue to provide credit secured by a bank account to military personnel and their spouses and dependents and may provide generic oral disclosures about payment obligations rather than the specific payment obligation of the individual borrower. Read ABA's Initial Staff Analysis . See ABA’s Regulatory Chart for more information. For questions, contact Nessa Feddis.
FinCEN Proposed Rule to Remove AML Program Exemption (8/25/16) The proposed rule would prescribe minimum standards for AML programs for banks without a Federal functional regulator to ensure that all banks are required to establish and implement AML programs to those banks not already subject to these requirements. Comments are due by October 24, 2016. Contact Rob Rowe for questions.