On December 20, 2016, the Consumer Financial Protection Bureau (CFPB) announced an enforcement action against Military Credit Services, LLC, for allegedly making loans with improper disclosures. In 2014, the CFPB took action against Military Credit Services, LLC, for similar disclosure issues.
The CFPB’s enforcement action determined that Military Credit Services, LLC, failed to properly disclose the terms of preauthorized transfers and interest rates on the loans it offered. Pursuant to the terms of the the consent order entered into with the CFPB, Military Credit Services, LLC, is required to:
- Ensure that its contracts, including its disclosures, comply with applicable laws;
- Hire an independent consultant to conduct an independent review of the company’s issuance and servicing of credit and provide an audit report to the CFPB; and
- Pay a $200,000 civil penalty.