Late last week, the Missouri Credit Union Association (MCUA) and the Defense Credit Union Council (DCUC) filed a comment letter with the Department of Defense (DoD) on the DoD’s advanced notice of proposed rulemaking regarding enhancement of the protections that apply to consumer credit extended to members of the armed forces and their dependents. MCUA urged the DoD to continue its targeted approach against abusive lending practices, which can harm the financial readiness of our troops and their families, and encourage the DoD to avoid unintended consequences for credit unions and others that provide quality financial products and services at reasonable rates.
MCUA understands the DoD may be concerned with other types of lenders, which offer predatory and abusive products that are not scrutinized by financial regulatory agencies. As such, MCUA strongly supports the imposition of firm enforcement actions on predatory and abusive entities, but urge the DoD to ensure regulated financial institutions, including credit unions, are not negatively impacted by future changes. Additional emphasis should be placed on financial education.