Ancillary products historically have been the subject of considerable litigation, regulatory, and governmental enforcement activity. They are now also under the microscope of the Consumer Financial Protection Bureau. The CFPB's concerns about the marketing and sale of ancillary products in the credit card area resulted in a series of significant consent orders with credit card issuers and the issuance of related guidance in CFPB Bulletin 2012-06.

Although the bulletin focuses on the marketing of credit card "add-on" products, it instructs institutions to consider this guidance when offering similar products in connection with "other forms of credit or deposit services." These developments foreshadow regulatory scrutiny of ancillary products sold in connection with auto finance and vehicle leasing transactions.

In this webinar, we will discuss topics relating to this looming regulatory scrutiny. 

Highlights

  • The history of regulatory scrutiny of ancillary products 
  • The CFPB's concerns and actions to date regarding ancillary products 
  • A discussion of the regulatory risks and suggested compliance measures for proprietary ancillary products and those of unaffiliated third parties
  • Likely CFPB concerns regarding ancillary auto financing and leasing products, including questions the CFPB will ask about your ancillary products 
  • Tips for performing compliance reviews of ancillary products and related marketing materials and disclosures

Program

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

Moderator

Alan S. Kaplinsky, Practice Leader
Consumer Financial Services Group

Presenters

Peter N. Cubita
Consumer Financial Services Group

John L. Culhane, Jr.
Consumer Financial Services Group

Christopher J. Willis
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 Prickril at prickrill@ballardspahr.com.

Related Practice

Consumer Financial Services