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Financial Services Law Insights and Observations

California Legislature Urges Congress to Request the Department of Defense Alter Criteria for Safe Harbor Provision in the MLA

State Issues State Legislation Military Lending Act Department of Defense Safe Harbor

State Issues

On September 25, the California Legislature filed a joint resolution that urges Congress to impress upon the Department of Defense the need to realign their criteria requiring a social security number for the safe harbor provision in the Military Lending Act (MLA). The resolution noted that the revised MLA regulations requiring lenders to ask for a social security number, among other information from borrowers, may expose lenders to liability under the California Unruh Civil Rights Act. It further states that this provision of the MLA could unnecessarily burden many segments of California’s immigrant communities.