Consumer Federation of America’s research has shown that the Military Lending Act has, to a limited extent, reduced the availability of high-cost credit such as payday lending and auto title lending. However, an analysis of state high-cost lending laws conducted by the Consumer Federation of America in March 2013 found that over half of service members are currently stationed in states where high-cost lending is widely available and are not subject to the interest rate cap or consumer protections provided by the Military Lending Act.

Based on this analysis of state laws that permit lenders to exploit definitional weaknesses and loopholes in the Military Lending Act and the rule that implements it, the Consumer Federation recommends that the Department of Defense examine forms of high-cost credit that are not currently subject to the prohibitions and protections established by the Military Lending Act rule and expand its definition of covered consumer credit to include all forms of high-cost credit commonly available to service members and their dependents.