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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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As reported by Law360, the U.S. Department of Justice (DOJ) has decided to move forward with its $68 million settlement with Colony Ridge Development LLC without seeking court approval or ongoing judicial oversight. The settlement at issue (discussed here) resolves DOJ and Texas reverse redlining and predatory lending claims in exchange for extensive operational reforms and $48 million in infrastructure improvements plus $20 million in law enforcement and public-safety spending, but no civil money penalties or direct monetary relief to borrowers.

On April 7, the Office of the Comptroller of the Currency (OCC) and the Federal Deposit Insurance Corporation (FDIC) issued a final rule to remove “reputation risk” from their supervisory and examination frameworks and sharply limit their ability to influence banks’ customer relationships based on political or ideological grounds. This final rule is a central implementation step for President Trump’s debanking initiative under Executive Order 14331, “Guaranteeing Fair Banking for All Americans,” which aims to address concerns about financial institutions improperly restricting access to banking services based on customers’ political, religious, or ideological beliefs.

In this special joint episode of The Consumer Finance Podcast and Payments Pros, guest host Taylor Gess joins Chris Willis and Lori Sommerfield to unpack fair lending risks in point-of-sale finance. They explain how traditional fair lending concepts under the Equal Credit Opportunity Act and Fair Housing Act play out when merchants interact directly with consumers, highlighting risks around discouraging credit applications, discretionary offers, differential assistance, and steering between prime and subprime products. The conversation explores practical risk mitigation tools, such as standardized sales scripts and consumer disclosures, merchant training, and attorney-directed mystery shopping, along with lessons drawn from unfair or deceptive acts or practices enforcement in point-of-sale settings.

The Federal Trade Commission (FTC) has taken a highly visible step into the national debate over “debanking” by sending warning letters to several large payment networks and financial services providers, reminding them that deplatforming or denying customers access to financial products or services due to political or religious beliefs could violate their existing obligations under Section 5 of the FTC Act. The FTC’s letters signal a sharpened enforcement focus on how financial services firms manage account closures, suspensions, and access to services, particularly when political or religious views are implicated.

In this episode of The Consumer Finance Podcast, Chris Willis is joined by Mark Furletti, James Stevens, and Taylor Gess to unpack the surge in bank charter applications from fintechs, crypto firms, and even traditional community banking entrepreneurs. The panel explores the appeal of national trust banks and industrial banks, as well as access to Fed payment rails and stablecoin issuance. They walk through the impacts of charter type, location, interest rate “exportation,” and preemption of state usury laws, including the nuanced role of branch-state activities. The conversation also offers a look at life inside the regulatory perimeter — exams, board oversight, and evolving supervisory focus — so nonbanks can realistically assess both the benefits and challenges of pursuing a bank charter in today’s regulatory environment.

In this episode of The Consumer Finance Podcast, Chris Willis is joined by Troutman Pepper Locke Partners Chad Fuller and Virginia Flynn for a practical, forward-looking discussion of the TCPA landscape as part of the CFS Year in Review and Look Ahead series. They explain how courts’ reduced reliance on agency interpretations is creating both opportunity and uncertainty, why plaintiffs’ attorneys are shifting hard toward do-not-call (DNC) and prerecorded-message theories, and how ongoing battles over consent, revocation, and text-message exposure are changing class action risk. The conversation closes with guidance for in-house counsel on tightening DNC compliance, managing vendors, and structuring consent and opt-out processes.

In this episode of The Consumer Finance Podcast, Chris Willis is joined by Consumer Financial Services Partners Stefanie Jackman and Nicholas O’Conner to dissect the shifting risk landscape for servicers, collectors, and debt buyers as federal scrutiny eases and state regulators surge to the forefront. As a segment of the Year in Review and Look Ahead series, the trio talks about Reg F’s post-Loper Bright staying power, the explosive growth of state medical debt restrictions and FCRA preemption battles, and the rapid spread of coerced debt/economic abuse statutes reshaping account handling. They also explore the evolving role of debt settlement companies and their use of AI, in addition to offering practical tips on building national policies and procedures to prepare for the next wave of litigation and enforcement.

This article was cited in the April 1, 2026 Multifamily Dive article, “FTC Seeks Public Input on Junk Fee Rule for Rental Housing.”

The Federal Trade Commission has announced an Advance Notice of Proposed Rulemaking (ANPRM) to explore a new rule governing unfair or deceptive rental housing fee practices. The initiative focuses on the widening gap between advertised rent and the total amounts renters actually pay once mandatory fees and charges are added. Once the ANPRM has been published in the Federal Register, comments will be accepted for 30 days. 

In this episode of The Consumer Finance Podcast, Chris Willis is joined by Troutman Pepper Locke Partners Heryka Knoespel and Mary Zinsner for a year-in-review and look-ahead tour through the sometimes wild world of UCC and banking litigation. From check cashers and sovereign citizens to elder financial exploitation, the panel unpacks the major trends banks faced in 2025, including a steady stream of retail deposit disputes and increasingly inventive plaintiff theories to recover funds — often running headlong into the UCC’s traditional allocation of risk.

In continuation of increased state efforts to regulate state-chartered banks and fintech partnerships,Oregon’s newly enrolled House Bill (HB) 4116 would enact an express “opt‑out” from a key provision of the Depository Institutions Deregulation and Monetary Control Act of 1980 (DIDMCA) for consumer finance loans made in Oregon. HB 4116 also updates licensing requirements and clarifies when Oregon law applies to remote and online loans. This Oregon development comes on the heels of the Tenth Circuit’s decision in Weiser upholding Colorado’s DIDMCA opt-out and holding that a loan is “made in such State” if either the borrower or lender is located in the opt-out state as discussed here. A petition for rehearing en banc has been filed in Weiser, and it remains unsettled where a loan is “made” for purposes of DIDMCA.