In this webinar, we will discuss the CFPB White Paper on Payday Loans and Deposit Advance Products and the OCC/FDIC Proposed Guidance on Deposit Advance Products. The White Paper and Proposed Guidance will have life-and-death implications for payday loans and deposit advances. They also will have enormous impact on mainstream consumer financial services products. Among other things, the White Paper and Proposed Guidance strongly suggest that the CFPB, OCC, and FDIC do not feel constrained to establish (or even analyze) whether consumer financial products meet Dodd-Frank's definitional standards for unfair, deceptive, or abusive acts or practices (UDAAP).

Highlights of the webinar will include an in-depth discussion of the following questions:

  • What statutory elements are required to establish a UDAAP violation?
  • Have the agencies established a basis for UDAAP findings regarding payday loans and deposit advance loans?
  • What further analysis is required? What do other studies and surveys show?
  • Are the OCC and FDIC usurping CFPB regulatory authority?
  • What other products are at risk? Overdrafts? High-rate lines of credit? Others?


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


Alan S. Kaplinsky, Practice Leader
Consumer Financial Services Group
Ballard Spahr


Jeremy T. Rosenblum, Practice Leader
Consumer Financial Services Group
Ballard Spahr

Hilary B. Miller
Law Offices of Hilary B. Miller

This program is open to Ballard Spahr clients and members of the financial services industry. 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 Prickril at

Program Contact

Lisa M. Prickril