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, and promotions, changes in terms, account closures, and collections.
A Partner in the Washington, D.C., office of Buckley LLP, Ms. Williams has extensive experience working with clients to develop credit programs, simplify credit agreements, adapt procedures for online and mobile environments, and implement, improve, and amend customer rewards programs. Ms. Williams helps companies sell their products over time, whether traditional banks with credit cards, online lenders with installment loans, startups with charge cards, or merchants with installment plans. She helps companies navigate the federal and state law governing credit, licensing, prohibitions on unfair, deceptive, or abusive acts or practices (UDAAP), limitations on lending to the military, and compliance with antidiscrimination laws.
She helps institutions evaluate fair lending issues in judgmental underwriting, advises financial institutions where to locate their card issuing banks to benefit from state laws on the exportation of interest rates, and assists merchants and emerging companies with implementing their credit programs. Ms. Williams assists lenders revise and refine key operational processes, disclosures, and customer agreements necessitated by changing legal standards. She also conducts training for in-house counsel on legal developments in the credit card industry, including compliance with emerging UDAAP standards.
Noteworthy work includes:
- Helping various professional football and basketball teams comply with consumer financing laws and payments system issues
- Assisting several online lenders launch installment, line of credit, and credit card operations, both in a bank partnership model and under state licenses
- Guiding major credit card issuers to structure credit cards rewards programs to adhere to best practices under evolving regulatory standards, evaluating credit programs for fair lending compliance, and launching new products such as prepaid cards, charge cards, and business credit
Before joining Buckley, Ms. Williams was Counsel with Wilmer Cutler Pickering, Hale and Dorr LLP, and prior to that she was a staff attorney at the Federal Reserve Board’s (FRB) Legal Division and Division of Consumer and Community Affairs, where she advised financial institutions on compliance with regulations including Regulations Z (Truth in Lending Act (TILA)), B (Equal Credit Opportunity Act (ECOA)), E (Electronic Fund Transfer (EFTs)), and CC (Availability of Funds and Collection of Checks).
Ms. Williams received her J.D. from Harvard Law School, an M.A. from Columbia University, and a B.A. from Stanford University. She organizes and hosts Card Roundtables where industry leaders discuss emerging issues in a congenial environment. She has a particular interest in financial literacy, and is a frequent presenter at public schools in the greater D.C. area, instructing students and teachers in understanding and using credit and debit cards, mobile phone plans, and other common consumer credit vehicles.
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...Articles
Special 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...Articles
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...Articles
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...Articles
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...Articles
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...Articles
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...Articles
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...Articles
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...Articles
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 (...Articles
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
- J.D., Harvard University, 1992 (magna cum laude)
- M.A., Columbia University, 1989
- B.A., Stanford University, 1987
- District of Columbia
- Staff Attorney in the Legal Division and the Division of Consumer and Community Affairs at the Federal Reserve Board