National Guard and Reserve MLA: Covered Only on Orders Over 30 Days

Yes, the Military Lending Act covers the National Guard and the Reserve, but only while you are on the right orders, and only for credit you open while on them. 32 CFR 232.3(g)(2) defines a covered member as a member of the armed forces serving on “Active duty pursuant to title 10, title 14, or title 32, United States Code, under a call or order that does not specify a period of 30 days or fewer,” or on “Active Guard and Reserve duty, as that term is defined in 10 U.S.C. 101(d)(6)” (read on ecfr.gov September 2, 2026). The statute, 10 U.S.C. § 987(i)(1), says “on active duty under a call or order that does not specify a period of 30 days or less,” or “on active Guard and Reserve Duty.” Status is measured “at the time the consumer becomes obligated” (§ 232.3(g)(1)), so the loan signed the day before orders gets nothing and the one signed the day after gets the 36% ceiling. What the MLA is and which credit it reaches have their own pages.

Orders type by orders type

The MLA column is the regulation’s text. The SCRA column comes from the Guard and Reserve SCRA guide, which walks the § 3911 test in full.

AGR. 10 U.S.C. § 101(d)(6)(A) includes full-time National Guard duty “for a period of 180 consecutive days or more for the purpose of organizing, administering, recruiting, instructing, or training the reserve components,” so a Title 32 AGR tour is covered through that definition. Section 101(d)(6)(B) carves out five jobs (Reserve Forces Policy Board, property and fiscal officers, counter-drug duty under 32 U.S.C. § 112, general and flag officers, state Selective Service directors); those fall back to the 30-day test.

Dependents. § 232.3(g)(3) borrows four classes from 10 U.S.C. § 1072(2): spouse (A); a child under 21, a full-time student under 23 you support, or an incapacitated child (D); a dependent parent or parent-in-law in your household (E); and a court-placed ward (I).

Title 32 orders: what the text supports, and what the database says

The statute, § 987(i)(1)(A), covers a member “on active duty,” and 10 U.S.C. § 101(d)(1) says that term “does not include full-time National Guard duty,” which is what orders under 32 U.S.C. §§ 316, 502, 503, 504, and 505 are under § 101(d)(5). On the statute alone, a Title 32 order looks excluded.

DoD’s 2015 regulation says “Active duty pursuant to title 10, title 14, or title 32,” and that is the text in force (ecfr.gov lists part 232 as last amended December 5, 2016). Unlike the SCRA’s § 502(f) national-emergency test, § 232.3(g)(2)(i) asks only whether the order specifies a period of 30 days or fewer. A 45-day § 502(f) order for a border mission or a hurricane passes on its face.

What the regulation cannot tell you is whether the DMDC database will agree. The MLA site’s home page describes the single record request as “a report certifying Title 10 active duty status for provisions under MLA,” and its FAQ “What is Title 32 vs Title 10 with respect to MLA?” never says whether Title 32 orders appear in results (read September 2, 2026). (That FAQ also says Title 32 “is paid by the state”; § 101(d)(5) says the member “is entitled to pay from the United States.”) So the regulation covers you, the database may not show it, and a lender that pulls a “no” and keeps the record holds a § 232.5 safe harbor even if the “no” is wrong. Run your own single record request on day one of any Title 32 order.

Fixed at opening, and ended at release

Two lines set the dates; most explainers mention only the first.

§ 232.3(g)(1) makes you a covered borrower if you are a covered member “at the time the consumer becomes obligated on a consumer credit transaction or establishes an account for consumer credit.” A card opened before the orders is never MLA credit, and going on orders later does not pull it in.

§ 232.3(g)(4) cuts the other way. Covered borrower “does not mean a consumer who (though a covered borrower at the time he or she became obligated …) no longer is a covered member.” The regulation’s own example, § 232.2(a)(2)(ii), walks a member who opened a line of credit on active duty and then left: “because Consumer A no longer is a covered borrower, this part no longer applies to the open-end line of credit.” DoD added (g)(4) in 2015 after card issuers asked about “account roll-off,” writing that § 987 “should apply only when the consumer … continues to be a covered borrower” (80 FR 43560, July 22, 2015).

A card opened during the orders is MLA credit for the rest of the orders and stops being MLA credit the day you are released; DoD’s 2016 interpretive rule lets a lender re-check the database to learn “whether a previously covered borrower retains that status” (81 FR 58840, question 10). Guides that say MLA credit is covered for the life of the account describe the active-duty case; on the text it lasts while you remain a covered member or dependent. The annual-fee waivers in the fee-waiver guide are voluntary programs keyed to the same database; how long an issuer keeps one after you leave the database is the issuer’s call. A closed-end loan keeps the rate in the note you signed on a covered day.

The database, the safe harbor, and why a “no” is final

§ 232.5 gives lenders two ways to a determination the regulation calls conclusive: the DoD database, or a covered-borrower indicator on a nationwide consumer report. The check must happen when you apply or within the 30 days before (§ 232.5(b)(3)), and § 232.5(b)(2)(i)(B) bans a lender from going back later “to ascertain whether a consumer had been a covered borrower as of the date of that transaction.” The covered-borrowers guide covers what that means in a dispute.

The regulation still prints the database address as www.dmdc.osd.mil/mla/welcome.xhtml. That address returned a 404 on September 2, 2026. The live site is mla.dmdc.osd.mil/mla/, and the 2016 interpretive rule calls the printed URL “a convenience” that does not limit the safe harbor (question 11). The live site says its services “are FREE”; an account is required (FAQ Q31); a search takes a nine-digit SSN or ITIN, last name, and date of birth; the certificate reports status “as of the date the search is performed” (Q21); and “Active Duty periods of less than 30 days of length are not included on the MLA website” (Q24). It is not the SCRA site in the DMDC website guide.

Worked example: 45-day orders, day 3 versus day minus 2

Orders: Title 10, October 5 through November 18, 2026, 45 days.

Version A. On October 3, two days before the orders start, you sign a $2,500 twelve-month installment loan at 99% APR. You are not yet a covered member, so part 232 never applies. Interest over the life of the loan: $1,532.57. Whether the SCRA’s 6% cap reaches it depends on the orders and on § 3917’s receipt-of-orders rule; see the activation cycle guide.

Version B. You wait until October 7, day three. You are a covered member under § 232.3(g)(2)(i). Under § 232.4(b) the lender “may not impose an MAPR greater than 36 percent,” and the MAPR counts fees, not just the rate (the MAPR guide has the math). At 36% with no fees, twelve months of interest is $513.86. The difference is $1,018.71, from moving the signature four days. A lender that will not write it at 36% must decline it.

A card opened October 7 is MLA credit through November 18, 43 days; on November 19 you are no longer a covered member and, under § 232.3(g)(4), no longer a covered borrower on that card. A card opened October 3 is never MLA credit, on that day or any later activation.

Time the application to the orders

1. Read the orders for the authority (title 10, 14, or 32, or a state statute) and the period. Thirty days or fewer, or state authority, means no MLA.
2. On day one, create an account at mla.dmdc.osd.mil and run a single record request on yourself. Save the certificate PDF within eight days.
3. Apply after the orders start and after the certificate reads positive, never before. Under 232.5 the check at application is the only one that counts.
4. Keep the orders, the certificate, and the first statement showing the rate and any waived fee.
5. Calendar the release date. Open-end coverage ends that day; ask the issuer in writing beforehand what happens to any fee waiver.
6. If a lender charged an MAPR above 36% on credit you opened while covered, dispute it in writing citing 32 CFR 232.4, then use the enforcement guide for remedies.

The law behind this: 10 U.S.C. § 987

Terms of consumer credit extended to members and dependents: limitations: read the statute.