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by the Consumer Financial Services Group
The Financial Crimes Enforcement Network (FinCEN) has published in the Federal Register its long-awaited final rule on "prepaid access" (formerly known as "stored value"). The result was worth the wait, with substantial improvements that should significantly reduce the regulatory burden the proposed rule would have created.
Highlights of the final rule include the following:
Ballard Spahr's Consumer Financial Services Group is nationally recognized for its guidance in structuring and documenting new consumer financial services products, its experience with the full range of federal and state consumer credit laws throughout the country, and its skill in litigation defense and avoidance (including pioneering work in pre-dispute arbitration programs). In addition to regularly counseling clients engaged in consumer debt collection on compliance with the Fair Debt Collection Practices Act and state debt collection laws, Ballard Spahr lawyers have extensive experience in defending all manner of debt collection lawsuits. For more information, please contact group Chair Alan S. Kaplinsky, 215.864.8544 or kaplinsky@ballardspahr.com; Vice Chair Jeremy T. Rosenblum, 215.864.8505 or rosenblum@ballardspahr.com; John L. Culhane, Jr., 215.864.8535 or culhane@ballardspahr.com; Mercedes K. Tunstall, 202.661.2221 or tunstallm@ballardspahr.com; Keith R. Fisher, 202.661.2284 or fisherk@ballardspahr.com; Barbara S. Mishkin, 215.864.8528 or mishkinb@ballardspahr.com; or Mark J. Furletti, 215.864.8138 or furlettim@ballardspahr.com.
Copyright © 2011 by Ballard Spahr LLP (No claim to original U.S. government material.)
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This alert is a periodic publication of Ballard Spahr LLP and is intended to notify recipients of new developments in the law. It should not be construed as legal advice or legal opinion on any specific facts or circumstances. The contents are intended for general informational purposes only, and you are urged to consult your own attorney concerning your situation and specific legal questions you have.