Consumer Federation of America, the Center for Responsible Lending, the National Association of Consumer Advocates, and the National Consumer Law Center (on behalf of its low-income clients) file this comment to the Department of Defense’s (DoD) Advanced Notice of Proposed Rulemaking (ANPR) regarding “Limitations on Terms of Consumer Credit Extended to Service Members and Dependents.” We appreciate the opportunity to respond to the DoD’s notice and support revision and expansion of the regulation beyond the current definition of “consumer credit” to protect our nation’s active-duty Service members and their dependents. The rule should apply to all consumer credit currently regulated under the Truth in Lending Act (TILA), to overdraft programs, and to rent-to-own transactions.