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MIL - Open-end and ODP Coverage

Question: 
The Military Lending Act does not specify if the Act applies to an open-ended Overdraft Protection line that is tied to a checking account or a closed-ended loan secured by the applicants’ deposit accounts such as a savings and/or certificate of deposit. Does the Rule apply to both consumer credit types?
Answer: 

The MLA has references to Reg Z, which defines “credit card” under 1026.2(a)(15)(i). Credit cards are covered. “Open-end” is separately defined at (20). Overdraft lines will fall under open-end credit.
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First published on 01/19/2020

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