MLA, SCRA Non-Rate Protections, Enforcement Pitfalls, Servicing Guidance
In-house counsel for consumer lenders, mortgage servicers, and financial institutions extending credit to servicemembers must review this analysis, as it details overlooked non-rate MLA and SCRA requirements and common enforcement missteps that expose firms to significant regulatory penalties.
This third installment of a servicemember protection series breaks down non-rate requirements under the Military Lending Act (MLA) and Servicemembers Civil Relief Act (SCRA) for consumer lenders and loan servicers. It details common servicing and compliance errors that trigger regulatory enforcement, clarifies ambiguous statutory and regulatory mandates, and highlights recent agency enforcement trends targeting firms that fail to meet full MLA and SCRA obligations. In-house counsel at covered financial institutions should use these insights to audit existing compliance programs and train origination, servicing, and frontline staff to mitigate enforcement risk.