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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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On August 11, the Colorado Department of Law (DOL) filed proposed rules implementing two significant Colorado artificial intelligence laws, the Automated Decision-Making Technology in Consequential Decisions Act (ADMT Act) and the Conversational Artificial Intelligence Services Act (Chatbot Safety Act), both of which take effect January 1, 2027. As we reported in May (here), the Colorado legislature significantly rewrote its earlier 2024 AI law, replacing the prior framework with a more targeted set of obligations focused on automated decision-making technology (ADMT) in consequential decisions. The proposed rules represent the Attorney General’s effort to flesh out that framework before the upcoming effective date. They also begin to answer several of the questions we flagged as unresolved when the new law was signed. A formal rulemaking hearing has been scheduled on October 26, 2026. Public comments about any proposed revisions to the rules to be presented during the hearing must be submitted by October 5, but all public comments submitted through October 26 will be considered for the final set of rules.

In this episode of The Consumer Finance Podcast, host Chris Willis sits down with Partners Joseph DeFazio and Joseph Froehlich to discuss the New Jersey Supreme Court’s ruling in Diana, a unanimous ruling and long-awaited victory for debt buyers operating in New Jersey. At the center of the conversation is a high-volume litigation campaign waged by the Kim Law Firm, which targeted the chain of title for consumer debts under the New Jersey Consumer Finance Licensing Act (NJCFLA). Kim’s core theory argued that any consumer debt under $50,000 — including personal loans, auto loans, and retail credit — that was ever touched, transferred, or assigned by an unlicensed entity is void and unenforceable as a matter of law, and that any attempt to collect on such a debt independently triggers statutory liability.

On August 7, the Federal Trade Commission (FTC) issued a policy statement announcing that it will no longer pursue claims based on disparate impact or “unfair discrimination” theories under any statute it enforces. The FTC’s action is the latest in a series of coordinated federal agency moves away from disparate impact enforcement. As we previously reported here, the Department of Housing and Urban Development (HUD) proposed to repeal its Fair Housing Act disparate impact regulations in January 2026, and the Consumer Financial Protection Bureau (CFPB) finalized its rewrite of Subpart A of Regulation B under the Equal Credit Opportunity Act (ECOA) in April 2026, eliminating the disparate impact “effects test” from ECOA enforcement and reframing ECOA as an intent-only statute (see here). Together with the FTC’s action, these developments signal a sweeping realignment of federal fair lending and consumer protection enforcement away from outcome-based theories and toward intentional discrimination as the operative standard.

On July 30, 2026, the Department of Justice (DOJ) announced that a “lease here, pay here” dealership operating across Mississippi, Alabama, and Georgia agreed to pay over $137,000 to resolve allegations that it violated the Servicemembers Civil Relief Act (SCRA). The case is a useful reminder of what the SCRA actually requires from auto dealers and finance companies in leasing and repossessions, and what can go wrong when those obligations are not met.

In this solo episode of The Consumer Finance Podcast, Chris Willis, co-leader of Troutman Pepper Locke’s Consumer Financial Services Regulatory practice, walks through the recent wave of federal regulatory guidance addressing the role of immigration status in consumer lending and explains why the practical impact on lenders may be far more limited than the public discourse suggests. Chris breaks down what each piece of guidance says, including the Consumer Financial Protection Bureau’s reminder that Regulation B permits immigration status considerations in ability-to-repay analyses for mortgages and credit cards, and the banking regulators’ safety and soundness and concentration risk warnings. He also addresses the competing litigation risks that complicate a simple return to restrictive eligibility policies. He then turns to the critical practical question: what, if anything, should lenders actually do?

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.