For those of you that didn’t have a chance to listen to the FFIEC’s Industry Outreach webinar on the Military Lending Act (MLA), it was mostly just an overview of the Rule itself. We did; however, get some additional information on a couple issues we’ve been unsure about:
1. You can finance the purchase of a vehicle, as well as amounts for an extended warranty, without losing your purchase-money exemption; and,
2. It appears you can take a security interest in a deposit account. This has been an ongoing source of confusion that the Q&A tried to clarify, but didn’t, at least as far as we were concerned. We now think you’re able to take a security interest in a deposit account because the borrower is granting it or giving it to you.
While this guidance is good news, we still wish the regulation itself was more clear on these issues. In any case, we hope this gives you some assurance!
Diane joined Banker’s Compliance Consulting with over 10 years of compliance experience and over 15 years of experience within the financial industry. Diane is a Certified Regulatory Compliance Manager (CRCM) and has a Bachelor’s Degree in Sociology with a concentration in Criminal Justice. She is a graduate of the Schools of Banking Compliance School and has participated in various other training opportunities throughout her career. Diane understands firsthand the struggles banks face in building and maintaining successful compliance programs. Her experience and common sense approach to consumer compliance is a great asset to our clients.
Diane and her husband have two kids who keep them busy. She enjoys running and other sports and is a big Bugs Bunny fan! She’s a bit crazy in that she does enjoy reading some of these regulations and she’s a “crazy cat lady!” Her cat tales are hilarious!