Service members and veterans need to be wary of new forms of credit-like products that have popped up in recent years, especially “paycheck advance” products and Income Share Agreements.
One problem for service members and veterans is that current legal protections may not cover these new “products.” For example, the Military Lending Act gives service members low interest rates on most forms of consumer credit and is documented to have successfully reduced service members’ use of payday loans since its 2006 enactment. But does it reach these new “products” that have popped up in recent years?
The term “credit” has a technical definition. The federal Truth in Lending Act (TILA) defines “credit” as the right granted by a “creditor” to “defer payment of debt or to incur debt and defer its payment.” A “creditor” is one who regularly extends credit that is either repayable in more than four installments or has a “finance charge.” Once a product is determined to be “credit,” important federal protections are triggered, like fee disclosures.
But there are some new products that might not be covered by the laws and that service members, veterans, military families and survivors should be wary of:
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Mike Saunders is the Director of Military and Consumer Policy at Veterans Education Success