The Consumer Financial Protection Bureau has proposed a larger participant rule that would enable it to supervise certain nonbank student loan servicers. (The CFPB already has the authority to supervise nonbanks that service private education loans originated by them, by other nonbanks, and by banks with more than $10 billion in assets.) The new rule would apply not only to nonbank servicers of legacy FFELP and private student loans, but also to entities that have contracted with the Department of Education to service federal student loans made by the government under the William D. Ford Direct Loan Program.

In this webinar, Ballard Spahr’s Consumer Financial Services Group will examine in depth the proposed rule and will explain in detail the rule’s consequences, not only for the top-tier student loan servicers, but for all mid-tier and lower-tier servicers of federal and private student loans as well. We will conclude with some concrete recommendations for servicers on preparing for CFPB oversight.


  • A review of the CFPB’s authority to regulate larger participants
  • A refresher on larger participant protocols of general applicability
  • An examination of the proposed market – student loan servicing
  • An explanation of how the CFPB will determine larger participant status
  • An analysis of the rule’s consequences for larger participants and their service providers
  • An analysis of the rule’s consequences for all other participants and their service providers
  • A reminder of how to challenge larger participant status
  • A discussion of how to prepare for CFPB oversight


12:00 PM - 1:00 PM ET | Webinar


Alan S. Kaplinsky, Practice Leader
Consumer Financial Services Group


John L. Culhane, Jr., Partner
Consumer Financial Services Group
Higher Education Group

Christopher J. Willis, Partner
Consumer Financial Services Group

There is no cost to attend. This program is not eligible for continuing education credits.

Please register at least two days before the webinar. Login details will be sent to all approved registrants. For more information, contact Lisa M. Prickril at

Program Contact

Lisa M. Prickril