The CFPB included a new report with its comment letter to the Department of Defense regarding proposed updates to the Military Lending Act. The report supported the CFPB's position that the tighter lending restrictions proposed by the DoD should be finalized as written.

The proposal included a broader definition of consumer credit that would prevent federal credit unions from making payday alternative loans permitted by an NCUA rule. The proposal would include any credit offered or extended to active-duty military members that has a finance charge or is payable under a written agreement in more than four installments. The proposed rules could be interpreted to include deposit advance products, more types of payday, auto title and installment loans, including open ended products like credit lines.

The CFPB said loopholes in the current Military Lending Act rules have allowed companies to skirt the rule's 36% rate cap and other military-specific credit protections.