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ABA: The American Bankers Association
Compliance News

ABA Publishes Staff Analysis of Amendments to MLA Interpretive Rule

ABA has published a members-only staff analysis on the Department of Defense’s recent withdrawal of a provision in its interpretive rule to the Military Lending Act regulations related to vehicle loans that finance Guaranteed Auto Protection, or GAP, and insurance credit.

The DoD last month said it would withdraw the existing Q&A 2, which related to the exclusions from the rule of purchase money loans. It also included a statement that vehicle purchase loans that also finance credit insurance, including GAP, are not exempt from the regulation. DoD has reverted to the previous Q&A 2, which would interpret loans used to purchase vehicles securing the loan as exempt even if they are used to purchase GAP and other products. For more information, contact ABA's Nessa Feddis.