The Consumer Financial Protection Bureau has issued its long-awaited proposed rule covering single-payment payday and auto title loans, deposit advance products, and certain high-rate installment and open-end loans. The proposal represents a sea change for companies providing these products.

In this webinar, we will discuss:

  • The comment process and time frame to the effective date of a final rule
  • The proposal's legal weaknesses
  • The companies and products covered by the proposal
  • The proposal's limitations and requirements for covered products, including:
    • The triggers for coverage of longer-term loans
    • Requirements for an ability to repay (ATR) analysis (and potential pitfalls)
    • Whether there exist any feasible alternatives to longer-term loans made with an ATR analysis
    • Limitations on collection attempts
  • Differences between the proposal and last year's SBREFA outline
  • The proposal's impact on the industry
  • How banks (and possibly other companies) can address the worst effects of the proposal
  • How the industry should respond

Date & TIme

Wednesday, June 15, 2016
12:00 PM - 1:00 PM ET


Alan S. Kaplinsky
Practice Leader
Consumer Financial Services


Jeremy T. Rosenblum
Practice Leader
Consumer Financial Services

Mark J. Furletti
Consumer Financial Services

James Kim
Consumer Financial Services

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 CLE credits.

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