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Does the Military Lending Act (MLA) permit creditors to make a loan to a covered person that is secured by a certificate of deposit?

ABA had sought clarification that military personnel may obtain loans secured by a bank account because of ambiguity on whether the condition that the loan comply with the MLA Rule included the provision that prohibits lenders from “accessing an account.” The revised Interpretive Rule now provides that the regulation does not prohibit lenders from providing loans secured by a bank account provided that it “complies with all other provisions of the MLA regulation…” (November, 2019)

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