I am trying to figure out when this becomes effective. I know the proposal says October 1. That is coming up soon.

Are bank's planning to stop offering certain products to military personnel? Do credit cards meet the definition of consumer credit? If anyone is willing to share what they have done to prepare to comply with this or comment, I would really appreciate it.

I think we're all holding our breaths waiting for the DOD to publish the final regulations.

10/1 is a statutory effective date, so with or without a regulation, new software, new forms, and staff training the law will go into effect. Anyone who cares about their reputation and CRA rating will think twice about discontinuing loans to military personnel and their dependents.

This isn't going to be pretty.

What the DOD Proposal said was that it would be limited to the following types of closed-end credit products:

-Payday Loans
-Car Title Loans
-Tax Refund Anticipation Loans

Will be interesting to see the final outcome. BOL has a good article on this topic here: BOL Proposal Article

Thanks for the comments. I had not seen anything yet from the various newsletters that I recieve. I guess based on Richard's comments we need to start preparing to comply with this even if the regulations are not final. October is just around the corner.