Capital One Bank, which spent $12 billion to acquire ING Direct and a $30 billion HSBC credit card portfolio this year, is expected to receive intense scrutiny from the Consumer Financial Protection Bureau as it merges those businesses into its main operations.

"The stakes are higher after the CFPB entered into three separate consent orders with three separate issuers," said Ballard Spahr partner Alan S. Kaplinsky, Practice Leader of the firm's Consumer Financial Services Group.

Mr. Kaplinsky said Capital One will be a test case for banks integrating new assets because, with the new CFPB scrutiny, "you spend even more time and you devote more attention to dotting the i's, crossing the t's, checking things that maybe in prior years you didn't focus on all that much. You really have to scrub a portfolio to make sure that you're not bringing on issues that you know the regulators may find problematic."

Related Practices

Bank Regulation and Supervision
Consumer Financial Services
Mortgage Banking