On September 29, 2014, the Department of Defense (DOD) published a proposed rule in the Federal Register to amend its regulation implementing the Military Lending Act (MLA), 32 C.F.R. Part 232, to significantly expand the scope of the MLA protections by reaching new types of creditors and credit products, including credit cards. DOD says in the Supplementary Information that the proposal is the result of a statutory requirement in the MLA to consult with the Consumer Financial Protection Bureau (CFPB) and the federal banking agencies “not less often than once every two years” to determine whether the MLA implementing regulation should be amended.

The CFPB issued a press statement in which the agency said it “strongly supports” the DOD proposal. The CFPB’s strong statement of support may be an indication that the agency played a key role in developing DOD’s proposal. Creditors, especially credit card issuers, should study the proposal closely to understand how the proposed MLA requirements may impact their operations and could result in an additional compliance regime for service members and their spouses and dependents.