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Chris Willis

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Chris is the co-leader of the Consumer Financial Services Regulatory practice at the firm. He advises financial services institutions facing state and federal government investigations and examinations, counseling them on compliance issues including UDAP/UDAAP, credit reporting, debt collection, and fair lending, and defending them in individual and class action lawsuits brought by consumers and enforcement actions brought by government agencies.

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The Federal Trade Commission (FTC) has taken a highly visible step into the national debate over “debanking” by sending warning letters to several large payment networks and financial services providers, reminding them that deplatforming or denying customers access to financial products or services due to political or religious beliefs could violate their existing obligations under Section 5 of the FTC Act. The FTC’s letters signal a sharpened enforcement focus on how financial services firms manage account closures, suspensions, and access to services, particularly when political or religious views are implicated.

In this episode of The Consumer Finance Podcast, Chris Willis is joined by Mark Furletti, James Stevens, and Taylor Gess to unpack the surge in bank charter applications from fintechs, crypto firms, and even traditional community banking entrepreneurs. The panel explores the appeal of national trust banks and industrial banks, as well as access to Fed payment rails and stablecoin issuance. They walk through the impacts of charter type, location, interest rate “exportation,” and preemption of state usury laws, including the nuanced role of branch-state activities. The conversation also offers a look at life inside the regulatory perimeter — exams, board oversight, and evolving supervisory focus — so nonbanks can realistically assess both the benefits and challenges of pursuing a bank charter in today’s regulatory environment.

In this episode of The Consumer Finance Podcast, Chris Willis is joined by Troutman Pepper Locke Partners Chad Fuller and Virginia Flynn for a practical, forward-looking discussion of the TCPA landscape as part of the CFS Year in Review and Look Ahead series. They explain how courts’ reduced reliance on agency interpretations is creating both opportunity and uncertainty, why plaintiffs’ attorneys are shifting hard toward do-not-call (DNC) and prerecorded-message theories, and how ongoing battles over consent, revocation, and text-message exposure are changing class action risk. The conversation closes with guidance for in-house counsel on tightening DNC compliance, managing vendors, and structuring consent and opt-out processes.

In this episode of The Consumer Finance Podcast, Chris Willis is joined by Consumer Financial Services Partners Stefanie Jackman and Nicholas O’Conner to dissect the shifting risk landscape for servicers, collectors, and debt buyers as federal scrutiny eases and state regulators surge to the forefront. As a segment of the Year in Review and Look Ahead series, the trio talks about Reg F’s post-Loper Bright staying power, the explosive growth of state medical debt restrictions and FCRA preemption battles, and the rapid spread of coerced debt/economic abuse statutes reshaping account handling. They also explore the evolving role of debt settlement companies and their use of AI, in addition to offering practical tips on building national policies and procedures to prepare for the next wave of litigation and enforcement.

The Federal Trade Commission has announced an Advance Notice of Proposed Rulemaking (ANPRM) to explore a new rule governing unfair or deceptive rental housing fee practices. The initiative focuses on the widening gap between advertised rent and the total amounts renters actually pay once mandatory fees and charges are added. Once the ANPRM has been published in the Federal Register, comments will be accepted for 30 days. 

In this episode of The Consumer Finance Podcast, Chris Willis is joined by Troutman Pepper Locke Partners Heryka Knoespel and Mary Zinsner for a year-in-review and look-ahead tour through the sometimes wild world of UCC and banking litigation. From check cashers and sovereign citizens to elder financial exploitation, the panel unpacks the major trends banks faced in 2025, including a steady stream of retail deposit disputes and increasingly inventive plaintiff theories to recover funds — often running headlong into the UCC’s traditional allocation of risk.

In continuation of increased state efforts to regulate state-chartered banks and fintech partnerships,Oregon’s newly enrolled House Bill (HB) 4116 would enact an express “opt‑out” from a key provision of the Depository Institutions Deregulation and Monetary Control Act of 1980 (DIDMCA) for consumer finance loans made in Oregon. HB 4116 also updates licensing requirements and clarifies when Oregon law applies to remote and online loans. This Oregon development comes on the heels of the Tenth Circuit’s decision in Weiser upholding Colorado’s DIDMCA opt-out and holding that a loan is “made in such State” if either the borrower or lender is located in the opt-out state as discussed here. A petition for rehearing en banc has been filed in Weiser, and it remains unsettled where a loan is “made” for purposes of DIDMCA.

In this episode of The Consumer Finance Podcast, Chris Willis and Lori Sommerfield unpack the rapid reshaping of the fair lending and UDAAP regulatory enforcement landscape as part of the Year in Review and Look Ahead series. They cover the federal government’s efforts to roll back use of the disparate impact theory, reduce redlining and other enforcement actions, and implement the new debanking initiative, along with the CFPB’s evolving expectations concerning ECOA and Section 1071, and growing state-level oversight as state attorneys general, state regulators, and new state AI/disparate impact regimes fill the federal gap. With long statutes of limitations and 2026 rulemakings ahead, they underscore why financial institutions cannot relax fair lending and UDAAP compliance, even amid apparent federal retreat.

In this episode of The Consumer Finance Podcast, host Chris Willis is joined by Consumer Financial Services Practice Group leadership Michael Lacy and Simon Fleischmann to preview the firm’s annual Consumer Financial Services Year in Review and Look Ahead publication. They describe how the publication provides concise summaries of the past year’s key trends, cases, and regulatory developments — along with informed predictions for 2026 and beyond — across areas such as consumer class actions, bankruptcy, credit reporting, digital assets, mass arbitration, mortgage and auto finance, payment processing, and privacy and data security. They also introduce an upcoming companion podcast series featuring several of the publication’s section authors.

On February 23, the New York Department of Financial Services (DFS) issued a proposed new Part 423 to Title 3 of the NYCRR to implement New York Banking Law Article 14‑B for Buy-Now-Pay-Later (BNPL) lenders. The proposal would move BNPL firmly into New York’s credit system, imposing licensing, supervision, disclosure, data privacy, and underwriting requirements on both interest‑free and interest‑bearing BNPL products offered to New York consumers. If adopted, the rule would take effect 180 days after the notice of adoption is published in the State Register, with a short transitional period for existing BNPL providers. DFS is accepting pre-proposal comments through March 5, 2026, after which the proposed rule will be published in the New York state register for a formal 60-day comment period.