Sara Emley

Sara Emley

BuckleySandler LLP

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Latest Publications


The New "Independent Ability to Pay" Requirement for Open-End Credit Under the Federal Reserve Board's Reg Z

The March 18, 2011 Regulation Z amendments adopted by the Federal Reserve Board clarify aspects of the open-end credit card rules adopted to implement changes to the Truth in Lending Act, under the Credit Card Accountability,...more


CARD Act's Ability to Pay Proposal Ignites Public Policy Debate

President Obama signed the Credit Card Accountability Responsibility and Disclosure Act of 2009 (CARD Act) on May 22, 2009. The CARD Act is intended to increase the disclosures associated with credit cards and prevent...more


Who's Entitled to a Credit Card? Perspectives on the Fed's Independent Ability to Pay Amendment

Americans are devoted to credit cards, with nearly $800 billion in credit card debt and other revolving credit outstanding at year-end 2010. This fixation on credit has led to some hard landings recently, with credit card...more


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