Manley Williams
Partner
Biography
Manley Williams counsels clients on the legal issues arising throughout the life cycle of their credit products – from design and marketing, to credit applications, periodic statements, promotions, changes in terms, account closures and collections.
Publications
Special Alert: Summary of CFPB's Prepaid Rule
I. Overview of the CFPB’s Final Prepaid Rule On October 5, 2016, the Consumer Financial Protection Bureau (Bureau) issued a final rule (Prepaid Rule) amending Regulations E and Z to extend consumer protections to prepaid card accounts. The new protections include pre-acquisition disclosures, error...
ArticlesSpecial Alert: Department of Defense Issues Interpretive Rule Regarding Compliance with the Military Lending Act
Today, the Department of Defense (“DoD” or “Department”) published in the Federal Register an interpretive rule regarding compliance with its July 2015 amendments to the regulations implementing the Military Lending Act (“MLA”). The July 2015 amendments will extend the MLA’s 36% military annual...
ArticlesCredit Cards 2016: Consumer Protection in Focus
The past year has seen heightened CFPB interest in the following areas: (i) deferred interest and rewards, (ii) limited English proficiency consumers, and (iii) the recent revisions to the Military Lending Act (MLA). Pursuing simplicity in the design of product features and closely following...
ArticlesConsumer Financial Services Answer Book 2016
The fifth edition of the Practising Law Institute’s Consumer Financial Services Answer Book was published this month, with 29 Buckley Sandler attorneys contributing to this leading desk reference. The 2016 edition of the Consumer Financial Services Answer Book continues to provide practitioners...
ArticlesSpotlight on the Military Lending Act, Part 2: Planning for Compliance
Compliance with the revised Department of Defense (“DoD”) regulations under the Military Lending Act (“MLA”) is not mandatory until October 3, 2016 or, for most credit cards, until October 3, 2017. However, as the recent implementation of the Dodd-Frank Act mortgage regulations shows, a year or...
ArticlesSpotlight on the Military Lending Act, Part 1: Did the Final Rule Improve on the Proposal?
On July 22, 2015, the Department of Defense (“Department”) released its final rule amending the regulations that implement the Military Lending Act (“MLA”), which means that a wider range of credit products—including open-end credit—offered or extended to active duty service members and their...
Articles6 Record Search Lessons From $43M Clydesdale Bank Penalty
Clydesdale Bank PLC was recently hit with a more-than-$43 million fine, largely because it failed to search for documents that should have been subject to its destruction policy, and for misleading consumers and its regulators about the searches. The U.K.’s Financial Conduct Authority (FCA), which...
ArticlesTrending: A Principles-Based Approach To US Financial Regs
While the United States has traditionally utilized rules-based policies, there has been a recent trend toward integrating principles-based policies and behavioral economics in regulating consumer financial products. For a framework of applying behavioral economics- and principles-based regulations...
ArticlesConsumer Financial Services Answer Book 2015
Buckley Sandler lawyers played a prominent role in the publication of this leading desk reference on consumer financial services, published by the Practising Law Institute. The 2015 edition of this publication continues to provide practitioners with a core understanding of the laws governing...
ArticlesSpecial Alert: Recent Regulatory Actions Impacting Virtual Currency Ecosystem
New York Virtual Currency Proposal Could Capture Certain Bank Products | CFPB Issues Consumer Advisory | CFPB Announces Acceptance of Consumer Complaints New York Virtual Currency Proposal Could Capture Bank Products, Card Rewards Programs On July 17, the New York Department of Financial Services (...
ArticlesThe British (Financial Regulatory Principles) Are Coming!
Regulation of financial products and services in the U.S. historically has relied on rules-based regulatory policy, governing business processes including disclosures relating to terms, pricing, structure and marketing. The U.K. has been a leader in applying principles-based regulation, which...
Articles
Education
- J.D., Harvard University, 1992 (magna cum laude)
- M.A., Columbia University, 1989
- B.A., Stanford University, 1987
Admissions
- District of Columbia
Government Service
- Staff Attorney, Legal Division and the Division of Consumer and Community Affairs, Federal Reserve Board