Ballard Spahr LLP

Ballard Spahr LLP is a Philadelphia-based law firm of more than 500 lawyers practicing throughout the United States in the areas of litigation, business and finance, intellectual property, public finance, and real estate. The firm is one of the largest in the United States according to The American Lawyer.

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Hilary Adams

Kurt R. Anderson

Richard J. Andreano, Jr.

Justin Angelo

Wendy Angus-Anderson

David L. Axelrod

Latest from Ballard Spahr LLP

Consumer Finance Monitor

This week’s podcast: The CFPB’s final innovation policies: what you need to know

By Barbara S. Mishkin on October 17, 2019

In this podcast, Paul Watkins, Director of the CFPB’s Office of Innovation, joins us to discuss the CFPB’s final trial disclosures, no-action letter, and FinTech sandbox policies. Topics covered include the elements of each policy and the protection from liability available, the role of pre-application discussions between the CFPB and applicants, and the CFPB’s plans to engage in outreach to other federal and state regulators to maximize the value of approvals. Click here to listen…

Consumer Finance Monitor

Director Kraninger testifies at House and Senate hearings

By Barbara S. Mishkin on October 17, 2019

CFPB Director Kraninger was the sole witness at a House Financial Services Committee hearing yesterday on the Bureau’s Spring 2019 semi-annual report and at a Senate Banking Committee hearing today on the report. At the House hearing, Director Kraninger came under harsh criticism from Democratic members, with one member reportedly calling Ms. Kraninger “absolutely worthless.” A primary focus of Democratic members was the CFPB’s settlements earlier this year such as those with Sterling Jewelers and NDG …

CyberAdviser

Analysis: Notice Provisions of CCPA Proposed Regulations

By Philip N. Yannella & Gregory P. Szewczyk on October 17, 2019

To the surprise of some, the proposed CCPA Regulations issued last Thursday don’t address many of the well-discussed ambiguities under the law (such as what “valuable consideration” means in the context of a sale of personal information). Rather, the proposed Regulations address a number of technical, nut-and-bolt type compliance issues concerning how businesses must make required privacy disclosures, provide opt-outs notices, verify and respond to consumer requests. We’ll discuss the issues the proposed Regulations don’t…

Consumer Finance Monitor

House Financial Services Committee to hold Oct. 18 hearing on AI and cloud computing

By Alan S. Kaplinsky on October 17, 2019

Tomorrow, October 18, the House Financial Services Committee’s Task Force on Artificial Intelligence is scheduled to hold a hearing entitled “AI and the Evolution of Cloud Computing: Evaluating How Financial Data is Stored, Protected, and Maintained by Cloud Providers.” There will be a live webcast of the hearing. The Committee Memorandum and related legislation can be found here. …

Consumer Finance Monitor

Federal banking agencies release tailoring rules

By Scott A. Coleman on October 17, 2019

On October 10, 2019, the Board of Governors of the Federal Reserve System (Board), together with the Office of the Comptroller of the Currency and the Federal Deposit Insurance Corporation, adopted a final rule to revise the criteria for determining the applicability of regulatory capital and liquidity requirements for large U.S. banking organizations and the U.S. intermediate holding companies of certain foreign banking organizations. The Board also adopted a final rule that establishes risk-based categories…

Consumer Finance Monitor

Montana Supreme Court to decide if healthcare provider’s use of prepaid cards to make refunds violated state law

By Alan S. Kaplinsky on October 16, 2019

An appeal now pending before the Montana Supreme Court could have significance for businesses that use prepaid cards to make refunds to customers. In Bratton v. Sisters of Charity of Leavenworth Health System, Inc., the plaintiff filed a lawsuit against SCL Health (SCL), her healthcare provider, in Montana district court alleging that SCL violated Montana law by directing its bank to issue two prepaid cards to the plaintiff to refund credit balances on her…

Health Care Reform Dashboard

Proposed Regulations Provide Additional Guidance on Individual Coverage HRAs

By Edward I. Leeds & G'nece Jones on October 16, 2019

The U.S. Department of the Treasury has issued proposed regulations addressing how individual coverage health reimbursement arrangements (ICHRAs) can comply with the Employer Shared Responsibility Payments (ESRP) requirements under the Affordable Care Act (ACA) and the nondiscrimination rules for self-funded medical plans under section 105(h) of the Internal Revenue Code. The proposed regulations follow a set of final regulations issued in June that establish rules for ICHRAs. ICHRAs present an alternative to traditional group health…

Consumer Finance Monitor

No order from SCOTUS on Seila Law cert petition

By Alan S. Kaplinsky on October 16, 2019

Although the Seila Law docket indicated that the briefs on Seila Law’s petition for certiorari were distributed for the U.S. Supreme Court’s October 11 conference, no order on the petition was among the orders issued by the Court yesterday. Seila Law’s petition seeks review of the Ninth Circuit’s decision that held the CFPB’s structure is constitutional. Soon before the October 11 conference, All American Check Cashing filed a Petition for a Writ of Certiorari Before Judgment…

Consumer Finance Monitor

CA Governor signs laws setting Financing Law rate cap, automatic deposit account exemption from levy

By Alan S. Kaplinsky on October 14, 2019

Last week, California Governor Newsom signed into law AB 539, which makes significant amendments to the California Financing Law (CFL), and SB 616, which creates a new exemption from levy for deposit account funds. The Governor signed AB 539 on October 10. Most importantly, the CFL amendments limit the rate of interest that may be imposed on loans of $2,500 – $10,000 to 36% plus the federal funds rate (which is currently hovering…

Consumer Finance Monitor

California AG releases proposed CCPA regulations

By Kim Phan & Philip N. Yannella on October 14, 2019

The California Attorney General’s Office released its long-awaited proposed CCPA regulations last week. The proposed regulations are 24 pages long, and address a number of important technical compliance issues including how businesses should: provide just in time notice to consumers of personal information collected; provide notice to consumers of the right to opt out of the sale of personal information; provide notice to consumers of financial incentives; provide a CCPA compliant privacy policy; provide methods for consumers to submit requests to…

Ballard Spahr LLP

Ballard Spahr LLP Blogs

Blog Authors

This week’s podcast: The CFPB’s final innovation policies: what you need to know

Director Kraninger testifies at House and Senate hearings

Analysis: Notice Provisions of CCPA Proposed Regulations

House Financial Services Committee to hold Oct. 18 hearing on AI and cloud computing

Federal banking agencies release tailoring rules

Montana Supreme Court to decide if healthcare provider’s use of prepaid cards to make refunds violated state law

Proposed Regulations Provide Additional Guidance on Individual Coverage HRAs

No order from SCOTUS on Seila Law cert petition

CA Governor signs laws setting Financing Law rate cap, automatic deposit account exemption from levy

California AG releases proposed CCPA regulations

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