Does MLA apply to loans that were originated prior to the October 3, 2016 implementation date? Or is it only applicable to newly originated loans?

Thanks in advance!

The regulation applies to loans for which applications were submitted prior to October 3, 2016 but closed on October 3, 2016 or after. The regulation applies to accounts opened or established on October 3, 2016 or after, regardless of the date of application. However, in determining whether an applicant is covered, according to the regulation and DoD’s August 2016 interpretive rule, banks may rely on military status information obtained through the DoD’s MLA database or from a credit bureau at the time of application (or 30 days prior) and any time from that time up to the time the account is established.

^^ From ABA guidance.

MLA applies to loans that were consummated on or after 10/3/2016, except for credit cards.

Just to be clear, the revised MLA is what is being referred to above.

The technically correct answer is yes, the MLA (in it's prior version) has existed since 2007 with the Talent Amendment (JWNDAA).