MLA - Open-end and ODP Coverage

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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 under 1026.2(a)(20). Overdraft lines will fall under open-end credit.

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