The Military Lending Act set an inclusive 36 percent annual rate cap for loans made to covered service members and their dependents, prohibited securing loans with checks, electronic access to bank accounts, vehicle titles, or allotment of military pay, and required that service members have access to the judicial system to resolve complaints. Only mortgages and auto finance loans were excluded from coverage of the act, with the Department of Defense authorized to write rules to define the types of credit to be subject to these protections. Rules to implement the Military Lending Act (MLA), written by the Department of Defense (D0D) after opportunity for comments from the public, took effect on October 1, 2007. DoD defined three products as consumer credit for purposes of applying rate caps and other protections in the law, including payday loans, car title loans, and tax refund anticipation loans, but did not include other forms of high-cost or harmful credit that had been included as problematic in the DoD Report to Congress, such as military installment loans and rent-to-own transactions. Five years after enactment of this landmark legislation, the Annie E. Casey Foundation requested that Consumer Federation of America prepare a report on the impact of the Military Lending Act on military consumers, on opportunities for additional protections, and on the larger policy debate over rate caps and credit protections.”
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