Comments to Department of Defense: Expanding Credit Protections for Service Members and Their Families


View this document (PDF)

Published: August 1, 2013

Although the Military Lending Act has resulted in significant improvements, Service members continue to be the target of predatory lenders. In 2012, members of the military filed 61,642 complaints with the Federal Trade Commission’s Military Sentinel system. Twenty-two percent of complaints filed by enlisted members were about debt collection, banks/lenders and credit cards.

The Department of Defense (DoD) invited comments on whether to expand the Military Lending Act, particularly focusing on whether DoD should expand the current law's definition of "consumer credit." CRL and other groups urge the DoD to significantly broaden the definition of credit covered under the law's 36% APR limit to include:

  1. All consumer credit regulated under the Truth in Lending Act
  2. Overdraft programs and
  3. Rent-to-own transactions

This would include all payday loans regardless of how they are structured or length of the term.