DCUC Members,
Over the weekend, we received a list of amendments to S. 2155: “Economic Growth, Regulatory Relief and Consumer Protection Act” which will be voted on in the Senate Committee on Banking, Housing, and Urban Affairs tomorrow.
While there are a number of amendments that would be beneficial, there are two that are of concern:
1. Proposed amendment #24 would allow the Bureau of Consumer Financial Protection to provide greater protection to service members. This is exactly the kind of proposal that leads to over regulation such as the 2015 Military Lending Act Amendments. Again, DCUC has always supported the overall intent of protecting service members from predatory lenders. However, there are always unintended consequences resulting from over-regulation such as credit unions potentially withdrawing from these types of loans and sending service members right back into the arms of predatory lenders.
2. Proposed amendment #29 would require consideration of Federal fines and penalties and violations of the Servicemembers Civil Relief Act and the Military Lending Act. This is also troublesome because the Department of Defense has yet to issue clear guidance on credit cards pending review by the Office of Management and Budget. We also learned OMB is still asking for supporting data on the initial guidance DoD issued last year. Without knowing exactly what “good” versus “bad” loan products look like, coupled with potential fines and penalties; this proposed amendment can produce more unintended consequences.
Checking with our sources, it is expected there are enough bi-partisan votes to pass the bill “as is” without any amendments. The underlying bill was a carefully crafted compromise by the co-sponsors and it is our understanding that unless there is agreement among those senators--amendments from both democrats and republicans will be defeated.
DCUC will keep a close watch and will provide an update following tomorrow’s vote.
Later on this afternoon, we are also meeting with the Deputy Assistant Secretary of Defense for Force Education to discuss ongoing MLA concerns as well as financial education in advance of Military Saves Week and the Blended Retirement System.
As always, thank you for your support.
V/R,
Tony
