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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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Yesterday, the federal banking regulators issued new interagency guidance directing supervised financial institutions to take a closer look at credit risk when lending to individuals who are not legally authorized to work in the U.S. The guidance, issued jointly by the Office of the Comptroller of the Currency (OCC), Federal Deposit Insurance Corporation (FDIC), and National Credit Union Administration (NCUA), follows a May 2026 Executive Order (discussed here) aimed at addressing perceived risks to the financial system arising from the extension of credit to the non-work authorized population.

On July 6, the Consumer Financial Protection Bureau (CFPB or Bureau) released its 2026 regulatory agenda, outlining its planned rulemaking initiatives across the pre-rule, proposed rule, and final rule stages. The agenda reflects the Bureau’s continued shift under the current administration toward deregulation, regulatory streamlining, and reconsideration of rules issued under prior leadership.

In this third installment of the special series on servicemember protections, Chris Willis is joined by colleagues Taylor Gess and Jeremy Sairsingh to explore the non-pricing protections under the Military Lending Act (MLA) and the Servicemembers Civil Relief Act (SCRA).

In this episode of The Consumer Finance Podcast, Chris Willis is joined by Erin Edwards and Simon Fleischmann to break down the most significant trends reshaping the consumer finance class action landscape. With a 25% year-over-year increase in federal class action filings and consumer protection claims leading the charge, the stakes are getting higher for financial services companies. The trio covers critical areas from recent cases to highlight information that every in-house legal team needs to understand about class actions, including the significance of precise class definitions and ascertainability, standing and concrete injury, and evidentiary examination. Whether you’re managing active litigation or building a proactive defense strategy, this episode delivers the insights and practical checklist you need to navigate the class action wave.

On June 25, the Federal Deposit Insurance Corporation (FDIC) issued a notice of proposed rulemaking that would significantly update and clarify its regulations governing the disclosure of confidential information, including confidential supervisory information. This is the first substantial revision to these rules in approximately 30 years. The proposal would amend 12 CFR Part 309 and add a new Part 306, with changes designed to reduce administrative burden, expand the ability of insured depository institutions (IDIs) to share confidential supervisory information without prior FDIC approval, and modernize and clarify the FDIC’s information disclosure framework. Comments on the proposed rule are due 60 days after publication in the Federal Register.

In this second installment of the special series on servicemember protections, Chris Willis is joined again by colleagues Taylor Gess and Jeremy Sairsingh to explore how the Military Lending Act (MLA) and the Servicemembers Civil Relief Act (SCRA) impose pricing restrictions that are far more complex than a standard state usury cap, and why that complexity must be accounted for at the product design stage.

On June 17, the Consumer Financial Protection Bureau (CFPB or Bureau) officially rescinded its December 2020 advisory opinion on special purpose credit programs (SPCPs) under Regulation B, which implements the Equal Credit Opportunity Act (ECOA). The rescission aligns with the Bureau’s recent views on SPCPs, including those expressed in the Bureau’s April 2026 final rule amending the SPCP provisions of Regulation B (the Final Rule) (discussed here).

As we have previously reported, the litigation over the attempted shutdown of the Consumer Financial Protection Bureau (CFPB or Bureau) has continued to move quickly through the courts. By way of background, the D.C. district court had granted a preliminary injunction requiring the CFPB to reverse its shutdown efforts, reinstate its workforce, and continue performing its statutory duties, finding that Acting Director Russell Vought’s actions were inconsistent with the Bureau’s statutory obligations under Title X of the Dodd-Frank Act. In our August 2025 post, we covered the D.C. Circuit panel’s decision vacating that preliminary injunction, holding that most of the National Treasury Employees Union’s (NTEU) claims belonged in the Civil Service Reform Act regime and that the remaining claims did not target reviewable final agency action. In our December 2025 post, we reported on the full court’s decision to grant rehearing en banc, vacate the panel’s judgment, and set an expedited briefing schedule. With the panel decision vacated, the en banc court took up the case with the partial stay continuing to govern the parties’ conduct in the interim.

In this episode of The Consumer Finance Podcast, Chris Willis sits down with Jason Cover and Colin Wilson to discuss the evolving world of auto-renewal and subscription compliance, including the FTC’s click-to-cancel rule, its Eighth Circuit setback, and the states racing to fill the gap. They also spotlight a first-of-its-kind municipal rule proposed by New York City and explain why, even in a deregulatory environment, UDAP authority and ROSCA mean the compliance pressure hasn’t gone anywhere. If your business involves subscriptions, recurring billing, or point-of-sale financing, this is a conversation you can’t afford to miss.

On June 10, President Trump sent to the Senate his nomination of Brian Johnson to serve as Director of the Consumer Financial Protection Bureau (CFPB or Bureau) for a five-year term. The CFPB has been without a confirmed, full-time director since former Director Rohit Chopra was fired on February 1, 2025 (discussed here).