The final regulations were announced in July 2015, and began going into effect last year. Meanwhile, CUNA and other trade groups have continued to seek clarification and changes for certain provisions they argue interfere with offering loans that benefit service members.

In February, CUNA told the Defense Department that it would collect data that “would demonstrate the adverse impact the MLA regulation is having on some credit unions' ability to lend to service members and their families.”

CUNA's economics department combed NCUA call reports and surveyed 3,500 members online. Among the 615 responding credit unions, the survey found:

• 58% of respondents said the MLA is burdensome, with 15% saying it was “very difficult” and 43% saying it was “somewhat difficult” to comply with.
• 59% need more clarity, with 27% “strongly” agreeing MLA guidance is unclear and 32% “moderately” agreeing.
• 11% have eliminated and 5% reduced share-secured loans because of the burden of MLA restrictions on the level of funds that can be counted as collateral.
• 2% have discontinued indirect car lending programs because of concerns about MLA definitions that conceivably could leave credit unions with worthless loans if consumer disclosures weren't properly made by the dealer originating the loan.
• 5% said they had at least one other product they eliminated because of MLA concerns. These included unsecured lines of credit, overdraft lines of credit, payday alternative loans and credit cards.

Based on NCUA call reports, CUNA found that credit unions with military fields of memberships experienced an unexpected decline in the number of unsecured personal loans per member from 2015 to 2016. The number of loans per member had been rising steadily from a low of 12.0% in 2011 to 14.5% in 2015.

“Based on this trend and with continued improvement in economic conditions, we would have expected the demand for loans to continue to rise. We estimated the ratio would continue to rise to 15.2% for 2016, yet the ratio decreased to 13.7%,” the May 11 letter said.

“Even more significant, while only 47% of non-military credit unions experienced decreases in their portfolios for PALs (Payday Alternative Loans) between fourth quarter 2015 and fourth quarter 2016, 86% of military credit unions experienced decreases in their portfolios for PALs during this same time-period,” it said.

Among all U.S. credit unions, PALs rose 9.5% to $129.5 million in 2016, accounting for 0.01% of the $847 billion in total loans outstanding Dec. 31, according to NCUA. By contrast, about $50 billion in payday loans were made in 2014.

Christopher L. Peterson, who had a hand in drafting the regulations, said the criticisms from credit unions involve tiny amounts of loans, but the changes they seek can create risks to service members by creating loopholes companies offering payday, title and other predatory loans have proven adept at exploiting.

Peterson researched the impact of payday lending on service members in the years preceding the MLA's passage, and went to work for the Consumer Financial Protection Bureau after its creation in 2011. He has recently returned to full-time teaching at the University of Utah.

Peterson said while the regulations might create some inconveniences for some credit unions, those inconveniences are well worth the protection they give service members. “My hope is that credit unions will be patient.”