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An expertly-staffed hotline, federal regulatory tools, policies and procedures, and unlimited reviews for small-to-medium community banks across the U.S. — the only all-inclusive banking compliance advisory. C/A’s nearly 1700 products and tools support 48 separate bank compliance areas –an unlimited-access Bank Compliance Library – conforms to the most recently published federal banking rules and regulations. Whether you are building institutional exam-readiness or a bank compliance program, C/A has all the resources, access, and availability for one membership subscription. Co-owned by the Virginia Bankers Association and 28 other state bankers associations across the country. Contact C/A’s Membership Development Team at (888) 353-3933 or at: info@compliancealliance.com. To learn more about C/A’s new Virtual Compliance Officer service or call (833) 683-0701.

Compliance Alliance Featured Q&A

Question:

Are both new auto loans and used auto loans within the scope of the exception under the Military Lending Act (MLA)?

Answer:

If the loan otherwise meets the scope of the exception for vehicle loans in the MLA, then the vehicle being purchased and securing the loan may be new or used. In other words, the exception in the MLA does not specifically require that the automobile in question be either new or used, as set out here: 

“…(1) Consumer credit means credit offered or extended to a covered borrower primarily for personal, family, or household purposes, and that is: 

(i) Subject to a finance charge; or 

(ii) Payable by a written agreement in more than four installments. 

(2) Exceptions. Notwithstanding paragraph (f)(1) of this section, consumer credit does not mean: 

…

(ii) Any credit transaction that is expressly intended to finance the purchase of a motor vehicle when the credit is secured by the vehicle being purchased;…”

https://www.ecfr.gov/current/title-32/subtitle-A/chapter-I/subchapter-M/part-232#p-232.3(f)

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