MLA and SCRA 102: Pricing Constraints and the Complexity of Interest Cap Compliance — Servicemember Protections Explained

MLA and SCRA 102: Pricing Constraints and the Complexity of Interest Cap Compliance — Servicemember Protections Explained

In this second installment of the special series on servicemember protections, Chris Willis [https://www.troutman.com/professionals/chris-j-willis/] is joined again by colleagues Taylor Gess [https://www.troutman.com/professionals/taylor-r-gess/] and Jeremy Sairsingh [https://www.troutman.com/professionals/jeremy-colin-sairsingh/] to explore how the Military Lending Act (MLA) and the Servicemembers Civil Relief Act (SCRA) impose pricing restrictions that are far more complex than a standard state usury cap, and why that complexity must be accounted for at the product design stage. The discussion dives into the practical complexity of each statute's unique definition of interest. The team breaks down how the SCRA's 6% cap applies to pre-service obligations, which fees count toward that cap, and how the requirement to retroactively reduce and forgive, not defer, interest creates significant system-of-record challenges. They also explain how the MLA's Military Annual Percentage Rate (MAPR) differs from a traditional Truth in Lending Act/Regulation Z Annual Percentage Rate, what charges must be included in the MAPR calculation, and how the bona fide fee exception for CARD Act credit cards works in practice. The episode closes with a discussion of the SCRA's often-overlooked anti-acceleration provision and the regulatory expectation that servicemembers be given the option of a cash refund for forgiven interest rather than automatic principal reduction. Stay tuned for Part 3, which will cover non-pricing protections under these statutes. Hosted by Simplecast, an AdsWizz company. See pcm.adswizz.com [https://pcm.adswizz.com] for information about our collection and use of personal data for advertising.

Point-of-Sale Finance Series: Regulation of Subscription and Auto-Renewal Plans

In this episode of The Consumer Finance Podcast, Chris Willis [https://www.troutman.com/professionals/chris-j-willis/] sits down with Jason Cover [https://www.troutman.com/professionals/jason-m-cover/] and Colin Wilson [https://www.troutman.com/professionals/colin-p-wilson/] to discuss the evolving world of auto-renewal and subscription compliance, including the FTC's click-to-cancel rule, its Eighth Circuit setback, and the states racing to fill the gap. They also spotlight a first-of-its-kind municipal rule proposed by New York City and explain why, even in a deregulatory environment, UDAP authority and ROSCA mean the compliance pressure hasn't gone anywhere. If your business involves subscriptions, recurring billing, or point-of-sale financing, this is a conversation you can't afford to miss. Hosted by Simplecast, an AdsWizz company. See pcm.adswizz.com [https://pcm.adswizz.com] for information about our collection and use of personal data for advertising.

MLA and SCRA 101: Servicemember Credit Protections and Compliance Risks

In this kickoff episode of a special series on servicemember protections for The Consumer Finance Podcast, Chris Willis [https://www.troutman.com/professionals/chris-j-willis/] is joined by colleagues Taylor Gess [https://www.troutman.com/professionals/taylor-r-gess/] and Jeremy Sairsingh [https://www.troutman.com/professionals/jeremy-colin-sairsingh/] to unpack the fundamentals of the Military Lending Act (MLA) and the Servicemembers Civil Relief Act (SCRA) — two laws that remain top enforcement priorities for federal regulators. They explain how these laws are rooted in military readiness and national security, and why that history matters for how regulators, courts, and the Department of Justice view compliance in the consumer credit space today. The discussion walks through the core building blocks: what types of credit products each law covers, how the SCRA's timing- and remedy-focused framework works, and who qualifies as a "covered borrower" or protected servicemember or dependent under each law. The team highlights practical compliance challenges, including the safe harbors for covered-borrower checks under the MLA, the critical differences between MLA and SCRA status checks, and the risks around repossessions and foreclosures when SCRA protections apply to pre-service obligations. Hosted by Simplecast, an AdsWizz company. See pcm.adswizz.com [https://pcm.adswizz.com] for information about our collection and use of personal data for advertising.

The Debanking Debate: Regulators, Risk, and Reality for Payments

In this special crossover episode of The Consumer Finance and Payments Pros podcasts, Carlin McCrory [https://www.troutman.com/professionals/carlin-a-mccrory/], Keith Barnett [https://www.troutman.com/professionals/keith-j-barnett/], and Chris Willis [https://www.troutman.com/professionals/chris-j-willis/] explore the federal government's increasing attention to "debanking" and what it means for payment processors, money transmitters, banks, and other financial services providers. They discuss recent federal initiatives and agency activity that have heightened scrutiny of decisions to onboard, maintain, or terminate customers and merchants, particularly where those decisions may be perceived as based on political or religious viewpoints. The conversation highlights emerging regulatory theories about when debanking could be treated as an unfair practice, and how those theories align with existing statutory and case law frameworks. The group also examines the interaction between legitimate risk management under the BSA and reputational risk. They close with practical takeaways for the industry, including the importance of revisiting risk and onboarding practices, aligning those practices with evolving regulatory expectations, and maintaining clear documentation to support decisions about customer and merchant relationships in a changing oversight environment. Hosted by Simplecast, an AdsWizz company. See pcm.adswizz.com [https://pcm.adswizz.com] for information about our collection and use of personal data for advertising.

Colorado's New ADMT Act: Repeal of the 2024 AI Law, Expanded Coverage, and What It Means for Financial Services

In this episode of The Consumer Finance Podcast, Chris Willis [https://www.troutman.com/professionals/chris-j-willis/] and Kim Phan [https://www.troutman.com/professionals/kim-phan/] unpack Colorado's brand-new Automated Decision-Making Technology (ADMT) Act, which repeals and replaces the state's much-criticized 2024 AI law. They explain the shift from "high-risk AI systems" to the broader ADMT framework, what it means for consequential decisions in lending and financial services, and how the statute's "material influence" standard can sweep in tools that do far more than make final credit determinations. Hosted by Simplecast, an AdsWizz company. See pcm.adswizz.com [https://pcm.adswizz.com] for information about our collection and use of personal data for advertising.