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April 9, 2008 - The Department of Defense (DoD) continues to consult with NASCUS state regulators about the memorandum of understanding (MOU) between state credit union regulators and DoD for enforcement of consumer lending regulations to the military.
The DoD general counsel completed its review of the MOU and state regulators are one step closer to having a finalized document. NASCUS met with the Conference of State Bank Supervisors (CSBS) and the National Association of Consumer Credit Administrators (NACCA) recently to discuss the DoD general counsel’s comments.
Currently, the DoD is finalizing its review process and evaluating individual input from state credit union regulators. When this process is complete, state regulatory agencies will have the chance to review the MOU draft a final time.
DoD is aware that the final MOU will have to be tailored by each state agency to meet the specific needs of the state. The Department continues to indicate its desire to work with each state individually to ensure the MOU is acceptable and meets the state’s needs
Additionally, the Consumer Compliance Task Force of the Federal Financial Institutions Examination Council (FFIEC) continues to discuss exam procedures to implement the consumer lending provisions. This task force includes a representative from FFIEC’s State Liaison Committee (SLC) to represent the concerns of state regulators. Currently the exam procedures have been presented to the Consumer Compliance Task Force and should be eligible for a final vote in May before they are shared publicly.
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