10 USC 2011

AMBA has been active throughout the development and implementation of the Military Lending Act. The MLA essentially places a 36% “Military Annual Percentage Rate” cap on all loans to military members and their dependents. AMBA’s continuing involvement in interpreting and applying the MLA statute and its implementing regulations is focused on ensuring fairness for both banks and their military customers.

10 USC 2667

Leases: non-excess property of military departments and Defense Agencies

The SCRA exists to prevent entities engaged in financial transactions with military members from taking unfair advantage of their long absences from home, deployments, and assignments abroad. AMBA’s role is to educate its members and to engage with government agencies on issues involving the application of SCRA to banks.

AMBA has been an active participant in recent efforts of the Office of the Comptroller of the Currency and the Federal Reserve Board to update their CRA implementing regulations. As the only voice of banks with large military customer bases, AMBA has called the attention of these agencies to the difficulties inherent in defining a global military community in CRA’s local geography terms. We’ve made some headway, but there is much more discussion needed to adapt this 1970s-era law to 2020s-era realities.

MLA interpretive guidance (2016)

Vol. 12, Ch. 33

Financial Institutions on DoD Installations

DoD Instruction 1000.00

July 2010

DoD Instruction 1000.15

DoD Instruction 1344.09