Revised Interagency Examination Procedures Regarding MLA
October 07, 2016 / Source: OCC
The Federal Financial Institutions Examination Council’s (FFIEC) Task Force on Consumer Compliance recently revised the interagency examination procedures for the Military Lending Act (MLA) of 2006, as implemented by 32 CFR 232, “Limitations on Terms of Consumer Credit Extended to Service Members and Dependents.”
The revised interagency examination procedures reflect U.S. Department of Defense (DoD) amendments to 32 CFR 232 as published in the Federal Register on July 22, 2015,1 and the DoD August 26, 2016 interpretive rule.2
This Office of the Comptroller of the Currency (OCC) bulletin publishes on the OCC’s website the revised interagency examination procedures for DoD’s amended requirements in 32 CFR 232, for which the compliance date is October 3, 2016 (with a later compliance date for credit card accounts).3
OCC examiners will use these revised examination procedures for examinations relating to MLA compliance that begin on or after October 3, 2016. Supervisory activities will focus first on evaluating a bank’s compliance management system and overall efforts to come into compliance, recognizing the scope and scale of changes necessary for each bank to achieve effective compliance. In addition, the OCC is incorporating the revised procedures into the OCC’s Comptroller's Handbook. When published, the Comptroller's Handbook guidance will supplement the interagency procedures.