On October 4, 2016, pursuant to Letter to Credit Unions 16-CU-07, the National Credit Union Administration (NCUA) stated that its examiners will accept credit unions’ “reasonable and good faith efforts” to comply with the Military Lending Act (MLA) rules that went into effect this week. The new MLA rule expands the number of products covered by MLA, meaning credit unions will have to revamp how they identify covered borrowers and services. National Association of Federal Credit Unions (NAFCU) Executive Vice President of Government Affairs and General Counsel Carrie Hunt said that while the NAFCU appreciates NCUA’s consideration of good faith efforts, the NAFCU still has concerns about the rules. The Defense Department’s has released recent interpretive guidance on the rules, but the NAFCU has noted ambiguities, particularly relating to hybrid purchase money loans and share-secured loans that some credit unions think could lead to litigation risk. NAFCU has urged the Federal Financial Institutions Examination Council to delay compliance examinations of the rules until March 3, 2017 – which would give the industry six months to test its systems.