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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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In this episode of The Consumer Finance Podcast, host Chris Willis is joined by Stephen Hayes, co-managing partner of Relman Colfax, to discuss targeted digital advertising, an unsettled area of fair lending. They examine where nonmortgage lenders stand today and under a future administration, the drift of ad models into underwriting and pricing, lessons from Fair Housing Act cases and settlements, and the potential application of disparate impact to ad delivery. They also cover the Consumer Financial Protection Bureau’s (CFPB) 2026 Reg B revisions limiting discouragement and guidance for lenders to build marketing compliance, all through a lens of unfair, deceptive, or abusive acts or practices (UDAAP) and surveillance pricing.

On October 14, the Office of the Comptroller of the Currency (OCC) released its final report on the results of its review of debanking at the nine then-largest national banks under its supervision by asset size, as part of its implementation of Executive Order 14331, “Guaranteeing Fair Access to Banking for All Americans” (EO 14331), which was issued in August 2025. The same day, the Consumer Financial Protection Bureau (CFPB) announced that it will investigate whether the banks featured in the report, and others, have complied with federal consumer financial protection laws. Together, these two regulatory actions signal that debanking is becoming a key focal point for both prudential and consumer financial protection examinations and supervision.

On October 6, the Colorado Department of Law (DOL) released an interim draft of its proposed rules implementing the Automated Decision-Making Technology in Consequential Decisions Act (ADMT Act) and the Conversational Artificial Intelligence Services Act (Chatbot Safety Act) (the Interim Draft). As we reported in August (here), the DOL filed its initial draft on August 11 (the August 11 Draft). After receiving more than sixty comments, the DOL made what it calls “significant, substantive changes.” Our view is that some of the changes were positive, but many of the problematic aspects of the August 11 Draft remain. The DOL’s cover letter also noted that it is open to alternatives to its definition of “Financial or Lending Service.”

In this episode of The Consumer Finance Podcast, host Chris Willis is joined by partners Erin Edwards, Jason Manning, and Joe DeFazio, along with special guest Matt Brooks, a partner in Troutman Pepper Locke’s Bankruptcy + Restructuring practice, to talk about the resurgence of both residential and commercial foreclosures in 2026 and what it means for financial services companies.

On October 9, Michigan Governor Gretchen Whitmer signed Senate Bill 198 into law as Act No. 113 of the Public Acts of 2026, enacting the Motor Vehicle Dealer Data Collection Act. The law took effect immediately upon signing and establishes a comprehensive framework governing how manufacturers, third parties, dealer data vendors, and authorized integrators may access, share, and use data generated or stored within a dealer’s systems.

On October 1, the Consumer Financial Protection Bureau (CFPB or Bureau) released its Fair Lending Report for 2025, documenting a significant overhaul of the Bureau’s fair lending program under current leadership. The report describes a deliberate pivot away from the enforcement priorities of prior administrations toward what the CFPB characterizes as a narrower, more statutorily-grounded approach focused on proven, intentional discrimination with identifiable victims. The report also notes that, consistent with President Trump’s agenda, the CFPB has prioritized implementation of several executive orders, including directives prohibiting unlawful debanking, terminating discriminatory preferences, and ending the use of disparate impact in enforcing federal fair lending laws.

In this special crossover episode of The Consumer Finance Podcast and Regulatory Oversight, Chris Willis, Stefanie Jackman, and Mike Yaghi discuss California Governor Gavin Newsom’s appointment of former CFPB Director Rohit Chopra to lead the state’s newly created Business and Consumer Services Agency (BCSA).

In this special crossover episode of Regulatory Oversight and The Consumer Finance Podcast, Chris Willis, Stefanie Jackman, and Mike Yaghi discuss California Governor Gavin Newsom’s appointment of former CFPB Director Rohit Chopra to lead the state’s newly created Business and Consumer Services Agency (BCSA).

This article was republished in insideARM on October 7, 2026.

On September 16, the Conference of State Bank Supervisors (CSBS) released a new supervisory resource designed to help state examiners assess the use and risks of artificial intelligence (AI) at state-chartered banks and state-licensed nonbank financial institutions. The publicly available framework also gives regulated institutions insight into examiners’ general approach, the types of questions they may ask, and the information they may request regarding an institution’s AI-based products, services, and tools.