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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 Troutman Pepper Locke Partners Lindsey Kress and Regina McClendon to analyze the complexities of the California Consumers Legal Remedies Act (CLRA). The discussion highlights recent amendments, including the prohibition on drip pricing, and examines strategic approaches for businesses facing potential litigation under this statute. With a focus on understanding the CLRA’s unique provisions and defenses, the episode offers valuable guidance for companies navigating consumer protection challenges in California, along with addressing class action risks and safe harbors.

On May 15, the Consumer Financial Protection Bureau (CFPB or Bureau) officially rescinded its May 2022 interpretive rule concerning the scope of state enforcement authority under § 1042 of the Consumer Financial Protection Act of 2010 (CFPA). According to the CFPB, this decision restores statutory limits on states’ authority and aligns enforcement actions with the original legislative intent of the CFPA. By restoring statutory limits and promoting joint actions, the Bureau seeks to streamline enforcement processes and ensure that both federal and state authorities operate within their designated boundaries.

On May 14, the Consumer Financial Protection Bureau (CFPB or Bureau) published a proposed rule to rescind amendments to its Procedures for Supervisory Designation Proceedings, originally adopted in 2022 and 2024. This proposal marks a significant shift in the Bureau’s approach to supervising nonbank entities. Public comments on the rescission will be accepted until June 13, 2025.

In this crossover episode of The Consumer Finance Podcast and Regulatory Oversight, Chris Willis, Kim Phan, and Stephen Piepgrass provide insights on a new joint privacy task force among several state AGs, known as the Consortium of Privacy Regulators. The consortium recently outlined goals to share state resources and align enforcement priorities regarding consumer harm and privacy rights. In response to an anticipated shift of regulatory scrutiny from federal agencies to state leaders, this episode focuses on specific steps financial services companies should consider when dealing with consumer privacy, data, complaints, and inquiries to ensure compliance and mitigate potential investigations and enforcement actions.

On May 9, the U.S. Senate Committee on Banking, Housing, and Urban Affairs announced that President Trump signed into law Chairman Tim Scott’s (R-SC) Congressional Review Act (CRA) resolution, effectively overturning the Biden-era Consumer Financial Protection Bureau (CFPB) rule on overdraft fees. Chairman Scott, who spearheaded the effort, emphasized that the rule would have imposed detrimental price controls on overdraft services, potentially leading to more unbanked individuals and fewer consumer options.

Today, the Consumer Financial Protection Bureau (CFPB or Bureau) announced the withdrawal of 67 regulatory guidance documents, including interpretive rules, policy statements, and advisory opinions that have been issued since the Bureau’s inception in 2011. The withdrawn guidance documents impact most federal consumer protection laws, including the Consumer Financial Protection Act of 2010 (CFPA), Fair…

Today, the U.S. Department of the Treasury announced President Trump’s intent to nominate Jonathan McKernan as the Undersecretary of Domestic Finance. The press release states that McKernan’s continued service at Treasury “will ensure that his experience and expertise are best put to advancing the President’s America First agenda.”

In this episode of The Consumer Finance Podcast, Chris Willis is joined by Troutman Pepper Locke Partners Joseph DeFazio and Jason Manning, along with Alison Grounds, founder and managing partner of Troutman Pepper Locke’s award-winning eDiscovery subsidiary, eMerge to discuss the evolving capabilities and advantages of eDiscovery. This episode highlights the significance of efficient processes in streamlining document review to enhance legal strategies, including setting clear policies for electronically stored information (ESI) and analyzing vast volumes of digital data with accuracy. As the use of AI becomes more prevalent across the consumer financial services industry, the speakers underscore the impact of leaning into eDiscovery and innovation to help uncover critical evidence early in litigation and response plans, as well as during regulatory investigations.

On May 2, Virginia Governor Glenn Youngkin signed Senate Bill 1212 (SB 1212) into law, introducing new requirements and prohibitions under the Virginia Consumer Protection Act. Specifically, SB 1212 targets the disclosure of mandatory fees and surcharges in consumer transactions.