141205 MLA Proposed Rule Comments_final.pdfThe Military Lending Act (MLA) sets a 36 percent rate cap on consumer credit for service members and authorizes the Department of Defense to define “consumer credit.” The existing definition is narrow and allows high-cost lenders to continue to target service members. This letter supports new proposed rules that expand the definition of “consumer credit” to include all forms of credit subject to the Truth in Lending Act and not excluded by the MLA. The letter also urges the Department to include overdraft programs and rent-to-own transactions in its definition of consumer credit.