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, DC office of Buckley Sandler 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 and abusive acts and practices, 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 Unfair, Deceptive, or Abusive Acts or Practices (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 Sandler, 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 DC area, instructing students and teachers in understanding and using credit and debit cards, mobile phone plans, and other common consumer credit vehicles.
On October 5, 2016, the CFPB issued its final rule on prepaid products, which both expanded the scope of its existing regulations on payroll cards and added significant new requirements. Payroll cards are the second largest segment in the U.S. open-loop prepaid product market and are the most...Webcast
On October 5, 2016, the CFPB issued its final rule on prepaid products. The rule was first proposed nearly two years ago and introduces significant new requirements in the rapidly growing market for prepaid cards and other prepaid financial products. Consumers put nearly $65 billion on prepaid...Webcast
Buckley Sandler Fair Lending Today 2016 Conference: Credit Cards and Non-Secured Consumer Lending: Where Did the Regulators Focus in 2015 and Where Will They Go Next?
Ben Olson and Manley Williams spoke about “Credit Cards and Non-Secured Consumer Lending: Where Did the Regulators Focus in 2015 and Where Will They Go Next?” at Buckley Sandler’s eighth annual Fair Lending Today Conference on Monday, March 14, 2016 in Washington, DC...Speaking Engagement
Manley Williams spoke at the ABA's Sixth Annual Institute on Consumer Financial Services Basics on Friday, October 9, 2015 in Arlington, VA. Her panel was titled "Truth-in-Lending." Click here to learn more about this event .Speaking Engagement
Stay abreast of recent rulemaking developments at the Consumer Financial Protection Bureau (CFPB) and the Department of Defense (DoD) by joining Buckley Sandler attorneys for a discussion designed to assist in-house legal and compliance staff. The discussion will be moderated by Benjamin Olson ,...Webcast
Buckley Sandler Fair Lending Today Conference: Credit Cards and Non-Secured Consumer Lending: Where Did the Regulators Focus in 2014 and Where Will They Go Next?
Valerie Hletko and Manley Williams spoke at the firm’s 2015 Fair Lending Today Conference on Monday, March 16 in Washington, DC. Their panel was titled, “Credit Cards and Non-Secured Consumer Lending: Where Did the Regulators Focus in 2014 and Where Will They Go Next?”...Speaking Engagement
To assist in-house legal and compliance staff with planning for 2015, Buckley Sandler attorneys provided an update on recent rulemaking developments at the Consumer Financial Protection Bureau (CFPB) and the Department of Defense (DoD). The discussion will be moderated by Benjamin Olson , former...Webcast
Buckley Sandler presented its inaugural CFPB Today conference on October 6, 2014 in Washington, DC. Manley Williams, Valerie Hletko and Benjamin Olson spoke on the "Payment Cards and Overdrafts in Focus" panel.Speaking Engagement
Buckley Sandler Fair Lending Today Conference: Credit Cards and Non-Secured Consumer Lending: How to Avoid Fair Lending and UDAAP Pitfalls
On March 17, Buckley Sandler hosted its annual Fair Lending Today conference. The full-day event covered fair lending and UDAP regulatory, enforcement, and litigation developments impacting mortgage originators and servicers, auto finance companies, credit card issuers, and consumer lenders. Manley...Speaking Engagement
Buckley Sandler presented its 2013 Fair Lending Today Conference on April 8, 2013 in Washington, DC. Manley Williams and Andrea Mitchell spoke on the "Fair Lending, UDAAP, and Credit Cards" panel. Click here to learn more about Fair Lending Today.Speaking Engagement
The 2012 Fair Lending Today Conference on the CFPB and Compliance, Regulatory & Litigation Issues in Today's Changing Enforcement Environment, hosted by Buckley Sandler LLP, was held on Monday, April 30, 2012. Andrea Mitchell and Manley Williams spoke on the "New CFPB Enforcement Priorities for...Speaking Engagement
Buckley Sandler LLP hosted its eighth annual Fair Lending Today conference in Washington, DC on March 13-14, 2016. The two-day event featured an evening of interactive roundtable discussions on fair lending issues, followed by a full day of seminars. The sessions were led by Buckley Sandler...In The News
Buckley Sandler LLP hosted its second annual CFPB Today conference in Washington, DC October 25-26, 2015. The two-day event featured an evening of interactive roundtable discussions on CFPB trends, followed by a full day of seminars and breakout sessions. The roundtables and seminars were led by...Press Releases
Buckley Sandler LLP hosted its annual Fair Lending Today conference in Washington, DC, March 15-16, 2015. The two-day event featured an evening of interactive roundtable discussions on fair lending issues, followed by a full day of seminars. The roundtables and seminars were led by Buckley Sandler...Press Releases
Manley Williams Quoted in Bank Safety & Soundness Advisor Article, "How Can You Avoid Emerging Credit Card Fair Lending Risk?"
Manley Williams was quoted in the Bank Safety & Soundness Advisor article, titled "How Can You Avoid Emerging Credit Card Fair Lending Risk?," on December 1, 2014. Manley Williams, a partner in the Washington office of Buckley Sandler LLP, said it may be legally defensible for banks to market...In The News
Manley Williams Quoted in Bank Safety & Soundness Advisor Article, "What You Need to Know About Proposed Prepaid Card Regulation"
Manley Williams was quoted in the Bank Safety & Soundness Advisor article, titled "What You Need to Know About Proposed Prepaid Card Regulation," on December 1, 2014. Manley Williams, a partner with Buckley Sandler LLP in Washington said “the proposal could crimp innovation with prepaid...In The News
Buckley Sandler LLP hosted its inaugural CFPB Today conference in Washington, DC October 5-6, 2014. The two-day event featured an evening of interactive roundtable discussions on CFPB trends, followed by a full day of seminars. The roundtables and seminars were led by approximately 30 Buckley...In The News
Manley Williams Interviewed for Top Legal News Article, "Next Up for the CFPB: Loyalty Points & Rewards Programs?"
Manley Williams was interviewed for the Thomson Reuters Top Legal News blog's September 29, 2014, article, "Next Up for the CFPB: Loyalty Points & Rewards Programs?" "Loyalty and rewards programs are ubiquitous," Williams explains. "Credit card issuers, hotels, airlines, and retailers offer...In The News
Partner Manley Williams was quoted in Evan Weinberger's article, "CFPB Sets Stage For New Credit Card Regulations," on October 2, 2013 on Law360. While industry representatives concede that the plans can be complex, they say it's because they involve relationships with outside vendors, among other...In The News
Partner Manley Williams was quoted in the June 19 Law360 article, "Banks Fear CFPB Credit Card Database Will Give Them Bad Rap." After the CFPB announced its plans to make the publicly available database in December, the credit card and banking industries said the agency did not have the right to...In The News
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...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...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