AMBA #2021-006
29 March 2021
On 24 March 2021, we recommended that until memoranda issued by the Army and Air Force suspending participation in Military Saves Month are superseded or rescinded, all bank branches operating on Army and Air Force installations should discontinue their Military Saves activities. This morning, the DoD Office of Financial Readiness clarified those memoranda.
In an email, Andy Cohen, the office’s director, advised that these memoranda are “addressed to and directed at [Army and Air Force] internal operations.” They are “not addressed to, or directed at, on-base financial institutions and [do] not limit an on-base financial institution’s business operations that occur within the lease of an on-installation financial institution and do not involve DoD participation.” In other words, your on-base banks may resume planning and executing its Military Saves Month activities as long as those activities, if they involve the Military Saves organization, do not also involve DoD participation.
I have set out my entire exchange with Mr. Cohen, appropriately highlighted, below. I recommend you keep it handy in the event your Military Saves activities are questioned by installation personnel.
All the best,
Steve
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Good morning Steve,
Thank you again for your emails concerning the Departments of the Army and Air Force, and the Consumer Federation of America’s Military Saves program.
The Military Departments’ acceptance and use of a 501(c)(3) non-Federal entities’ (NFE) resources in providing installation financial education programs and materials is primarily governed by DoDI 1344.07. The DoDI details certain actions required by both the Military Department and NFE concerned. In addition to meeting these requirements, the DoDI provides the Military Departments discretion in approving NFEs and accepting their programs or materials for use, to ensure such resources meet the Services’ needs as determined by each Service.
Military Departments may be engaged in pre-decisional or other transactional activities involving an NFE which may involve a number of areas such as compliance, terms of service, or items of a proprietary concern to an NFE’s business operations. Therefore, it is not appropriate for the Department to publicly discuss these activities with the general public or other third parties, such as another NFE. However, I can share that both the Army’s’ and Air Force’s actions are consistent with the DoDI and other DoD policy guidance, to include the FMR.
While your association and some of its members may have individual relationships with an NFE that may have, or seeks to have, a relationship with DoD, to include its Military Departments, such relationships remain separate and distinct from one another.
The Army and Air Force memorandums are addressed to and directed at their internal operations and are within the scope of the FMR and DoDI. The memorandum is not addressed to, or directed at, on-base financial institutions and does not limit an on-base financial institution’s business operations that occur within the lease of an on-installation financial institution and do not involve DoD participation. This is consistent with my January 7, 2019 email to you addressing earlier questions you raised regarding the Department’s December 2018 memo.
This response was coordinated with OUSD(C), DFAS, and the Military Departments.
Best regards,
Andy
Andrew H. Cohen
Director, Office of Financial Readiness
Office of the Deputy Assistant Secretary of Defense (Force Education & Training)
Office: 703-692-5286
Mobile: 703-901-7145 Please use this number due to COVID-19 teleworking.
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From: Steven Lepper <Steven.Lepper@ambahq.org>
Sent: Tuesday, March 9, 2021 4:24 PM
To: Cohen, Andrew H CIV OSD OUSD P-R (USA) <andrew.h.cohen.civ@mail.mil>
Cc: Andia Dinesen <Andia.dinesen@ambahq.org>
Subject: [Non-DoD Source] 2021 Military Saves Campaign
Andy,
It has come to my attention that the Air Force has issued a “cease-and-desist” order precluding its Airmen and Family Readiness Centers from participating in this year’s Military Saves Campaign. I’m writing today to express my concern.
Two years ago, your office issued a memorandum to the Services announcing that 2019 Military Saves Week would be optional. Although this reflected a very significant change in approach from one that had traditionally and strongly supported MSW, many installations continued promoting the program through their banks, credit unions, and financial readiness organizations. Due to the pandemic last year, MSW activities were somewhat muted. Nevertheless, neither DoD nor the Services banned them altogether. The Air Force’s decision this year is surprising and detrimental to the financial welfare of our Airmen and their families. Unless DoD corrects the misperception that the MSW program is somehow contrary to DoDI 1344.07, we fear the other Services will soon follow the Air Force.
As you know, the Military Saves program simply promotes the value of saving money. Through its financial education programs and the savings pledges it solicits from military members and their families, it increases awareness of the need for savings among individuals who previously either ignored or underestimated its wealth-building effects. No financial products or services are promoted or sold. To the extent that the program encourages members of the military community to use bank or credit union savings accounts for the purpose of saving money, it is a generic recommendation, not the promotion of any particular bank or credit union. In other words, nothing Military Saves does violates DoDI 1344.07. In fact, it is entirely consistent with paragraph 6.7.5., which provides that “banks and credit unions operating on DoD installations are required to provide financial counseling services” because on-base banks and credit unions typically run the program.
In addition to my comments above, three facts compel DoD’s and the Military Services’ reinstatement and future support of the Military Saves program:
- COVID-19 has placed military families under unprecedented financial stress. According to a recent NFCC survey, the number of active duty service members who are worried about their personal finances increased significantly in the past year.
- The same study revealed that 70% of service members agreed that they could benefit from professional financial advice, but only 19% of them said they would trust the military to provide it.
- Finally, active duty service members were two times more likely to have taken out a cash advance or payday loan in 2020 than in 2019.
In this environment illustrated by these survey results, can DoD really afford NOT to resurrect its traditional but now dismantled partnerships with competent and capable private sector organizations so that, together, we can solve these difficult military financial readiness problems?
Thanks for listening. I hope you will seriously consider reversing this disappointing and damaging course.
Steve