Bank and CU Regulators Differ on MLA Compliance

While banks and credit unions are subject to many of the same laws and regulations, there are differences in how bank and credit union regulators examine their respective institutions with regard to compliance to these laws and regulations.

The latest example regarding the different approaches employed by bank and credit union regulators involves early testing for compliance with the Military Lending Act (MLA).

According to Ballard Spahr's CFPB Monitor,

"On September 29, the FFIEC released revised Interagency MLA examination procedures that appear parallel to those issued by the Bureau. The release of these updated procedures suggests that regulators do not intend to postpone transactional testing for MLA compliance as trade groups had requested. In contrast, the NCUA has instructed examiners to accept a credit union’s reasonable and good faith efforts to comply with the final rule during the first examination following the implementation date."

Once again, NCUA is the kinder and gentler regulator.