FWIW, I called DoD on an MLA issue and was told on that question that they didn't currently have an answer but that it, and other questions they have received, will be answered in a guidance document and that is expected in early July. I don't have other details but it does mean don't finalize policies or procedures prematurely.

Thanks Andy! That is good to know. I know that CUNA (as well as others I am sure!) has been hounding them as well for a guidance document!

Have you seen this? It's both a good list of some of the key problems with MLA as amended as well as the proposed solutions from a significant number of industry groups.

http://www.aba.com/Compliance/Documents/MLA-ProposedSolutions2016Apr.pdf