Compliance Alerts

DEPARTMENT OF DEFENSE INTERPRETIVE RULE

On December 14, 2017, the DoD issued an interpretive rule regarding the 2015 Military Lending Act (MLA). The interpretive rule sought to clarify certain exceptions under the Act. The rule states that credit-related products or services-as opposed to a product or service expressly related to a motor vehicle or personal property-are not eligible for the exceptions under § 232.3(f)(2)(ii) and (iii). 

The DoD sites specific examples such as:

•  The inclusion of financing for optional leather seats and an extended warranty for service would not disqualify the transaction for the exception.

• The inclusion of financed Guaranteed Asset Protection (GAP) or credit insurance would disqualify the transaction for the exception.

Effective December 14, 2017.