The Office of the Comptroller of the Currency’s (OCC) Bulletin 2014-37 on Consumer Debt Sales reflects the agency’s latest guidance on this topic since its written statement a year ago to the Senate Subcommittee on Financial Institutions and Consumer Protection describing “best practices” drawn from experience in supervising the largest national banks. Unlike the statement, which described risk management practices examiners should expect to find in large banks with debt sales activities, the Bulletin addresses the application of consumer protection requirements and safe and sound banking practices to debt sales by all OCC-supervised institutions, including community banks.

In this webinar, we will focus on the scope and provisions of the new Bulletin, explain how such guidance compares with prior pronouncements on the topic, and discuss its implications for the debt sales industry. We will also report on recent activity by the Uniform Law Commission, and conclude with recommendations for national banks, federal thrifts, and other debt sellers and buyers in confronting the potential industry changes resulting from the new guidance.


  • Examination of OCC Bulletin 2014-37 requirements and applicability
  • Discussion of distinctions and implications for the industry 
  • Update on recent Uniform Law Commission activity 
  • Recommendations for dealing with the new guidance and best practices     


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


Alan S. Kaplinsky, Practice Leader
Consumer Financial Services Group


John L. Culhane, Jr.
Consumer Financial Services Group

Keith R. Fisher
Consumer Financial Services Group 

Glen P. Trudel
Consumer Financial Services Group

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 M. Prickril at

Related Practices

Bank Regulation and Supervision
Consumer Financial Services
Mortgage Banking

Program Contact

Lisa M. Prickril