New Military Lending Act Requirements for Credit Cards, Effective October 3, 2017


Recording available Friday, August 18, 2017

The Department of Defense’s (DoD) credit-card-specific amendments to the Military Lending Act (MLA) regulations become effective on October 3, 2017. While lenders have had to comply with the non-credit card MLA changes since October 3, 2016, the DoD gave an extra year of implementation time for the credit card requirements. This additional time was necessary due to the detailed requirements that credit card issuers must meet. Importantly, the MLA requirements apply to all credit card issuers, including those who only serve a handful of military personnel, because the DoD’s credit card requirements apply whenever the card issuer establishes a credit card account for a “covered borrower” on or after October 3, 2017.

All credit card issuers will need to analyze their fees, review and adjust procedures, work with third-party vendors, and train staff to comply with the new requirements. This webinar will summarize the new credit card requirements and the steps to comply. The DoD’s tests for “bona fide and reasonable” credit card fees will be addressed, as will the complex requirements related to understanding the military annual percentage rate (MAPR) calculation for credit card accounts. Strategies for handling situations where the MAPR for a particular billing cycle would exceed the 36 percent limitation will also be covered.

Continuing Education: Attendance verification for CE credits upon request


  • Analysis of new credit-card-specific requirements from the Military Lending Act
  • Review of the safe harbor methods for determining the "covered borrower" status of credit card borrowers
  • DoD's tests and safe harbor provisions for "bona fide and reasonable" credit card fees
  • Analysis of the MAPR calculation and special issues related to credit card accounts
  • Action items before the October 3, 2017 compliance deadline

    • Summary of new Military Lending Act requirements for credit card accounts
    • Employee training log
    • Quiz you can administer to measure staff learning and a separate answer key


This informative session is designed for compliance, audit, lending, and operations staff of credit card issuers.

PLEASE NOTE: Program content is subject to copyright and intended for your individual financial institution’s use only.