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Do overdraft products fall under the definition of consumer credit under the Military Lending Act?
The interpretive rule states that in general, creditors are to look to the provisions of Regulation Z in determining whether a product or service is considered "consumer credit" (232.3) for the purposes of MLA. While the definition of consumer credit is not exactly the same as in Regulation Z, it is consistent with the definition under Regulation Z.
To determine whether the bank’s overdraft product or service is “consumer credit” under the MLA, depends on whether the product or service meets each element of the definition of “consumer credit” and whether an exception applies.
Reference: Interpretive Rule issued August 26, 2016 Q1.