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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, Chris Willis is joined by Mary Zinsner and Heryka Knoespel, partners in Troutman Pepper Locke’s Consumer Financial Services Practice Group, to discuss the latest in deposit account-related litigation. As part of the Year in Review and Look Ahead series, they delve into significant cases from 2024, including Ponzi schemes, check washing, and elder exploitation scams. They also provide insights into what depository institutions can expect in 2025. Tune in to stay informed about the evolving legal landscape affecting banks and credit unions.

On February 11, President Donald Trump nominated Jonathan McKernan to be the new Director of the Consumer Financial Protection Bureau (CFPB or Bureau). If confirmed by the Senate, McKernan will replace Acting CFPB Director Russell Vought, who also serves as the head of the Office of Management and Budget. McKernan was reportedly on the Trump administration’s short list of potential candidates to lead the CFPB and is considered an ally of the financial services industry.

Today, the U.S. District Court for the Northern District of Texas issued an order in Chamber of Commerce of the United States of America v. Consumer Financial Protection Bureau (CFPB or Bureau) in light of recent changes within the Bureau’s leadership.

On Friday, the U.S. Court of Appeals for the Fifth Circuit ordered the tolling of compliance deadlines for the Consumer Financial Protection Bureau’s (CFPB or Bureau) Small Business Lending Data Collection final rule under Section 1071 of the Dodd-Frank Act (the 1071 Rule). As we previously reported here, the CFPB had asked the appeals court for a pause last Monday to allow the new administration time to consider its position on the 1071 Rule. The CFPB also conveyed that it did not object to the plaintiff trade associations’ earlier motion to toll compliance deadlines, a change-of-position that led to Friday’s order.

In a dramatic series of events, the Consumer Financial Protection Bureau (CFPB or Bureau) has undergone leadership changes, signaling a significant shift in its regulatory approach. These changes began with the firing of Director Rohit Chopra by President Donald Trump and have continued with the resignation of General Counsel Seth Frotman and the appointment of Russell Vought as Acting Director.

In this third episode of the Year in Review series of The Consumer Finance Podcast, host Chris Willis is joined by Lori Sommerfield, a partner in Troutman Pepper Locke’s Consumer Financial Services Practice Group, to discuss significant fair lending and Unfair, Deceptive, or Abusive Acts or Practices (UDAAP) developments during 2024 and what to expect in 2025. They delve into aggressive redlining enforcement actions by federal regulators under the “Combatting Redlining Initiative” during the Biden administration, federal and state regulators’ increasing scrutiny of the use of artificial intelligence in consumer lending and potential discrimination claims, the Consumer Financial Protection Bureau’s war on “junk fees,” and the current status of the Section 1071 final rule. They also offer predictions concerning anticipated changes in the federal agencies’ approach to fair lending and UDAAP enforcement under the Trump administration. Tune in for a comprehensive overview and expert insights into these pivotal areas of law, which pose significant regulatory, legal, and reputational risk.

On February 4, Senators Bernie Sanders (I-Vt.) and Josh Hawley (R-Mo.) introduced bipartisan legislation aimed at immediately capping credit card interest rates at 10% for a period of five years. This initiative follows a recent Forbes report indicating that the average credit card interest rate stands at 28.6%.

Hours before a scheduled hearing yesterday, the Consumer Financial Protection Bureau (CFPB or Bureau) filed an “Emergency Notice” in the U.S. Court of Appeals for the Fifth Circuit with respect to the ongoing litigation challenging the CFPB’s Small Business Lending Data Collection final rule under Section 1071 of the Dodd-Frank Act (the 1071 Rule), discussed here. The notice announced that, with the removal of CFPB Director Rohit Chopra over the weekend, “Counsel for the CFPB has been instructed not to make any appearances in litigation except to seek a pause in proceedings.” The notice is in line with an email that went to all CFPB staff yesterday, directing staff to halt most all of the CFPB’s activities in connection with the appointment of Treasury Secretary Scott Bessent to serve as the agency’s Acting Director (as discussed here). The CFPB is also seeking a “pause” in other litigation and, presumably, is halting non-public enforcement proceedings as well.

In a significant and highly anticipated move, President Donald Trump has fired Rohit Chopra, the Director of the Consumer Financial Protection Bureau (CFPB or Bureau). Rohit Chopra, who had been serving as the Director of the CFPB since 2021, confirmed his departure in a letter to President Trump dated February 1, 2025. Chopra’s tenure was characterized by aggressive efforts to curb what he termed as “junk” fees and regulate Big Tech’s financial services.

In this episode of The Consumer Finance Podcast, host Chris Willis is joined by James Kim and Jesse Silverman, co-leaders of Troutman Pepper Locke’s fintech industry group. They discuss the current regulatory environment for earned wage access products, as well as potential developments in 2025. The conversation covers the evolving positions of the Consumer Financial Protection Bureau (CFPB) and the differing approaches taken by states such as Connecticut, Wisconsin, California, and Maryland. Tune in to understand the complexities and practical implications for earned wage access providers in this dynamic regulatory landscape.