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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 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.

On May 1, the U.S. Court of Appeals for the Fifth Circuit dismissed the Consumer Financial Protection Bureau’s (CFPB or Bureau) appeal concerning the vacated amendments to its Unfair, Deceptive, or Abusive Acts and Practices (UDAAP) Examination Manual. This dismissal, following a joint stipulation by the parties, aligns with the CFPB’s newly announced supervision and enforcement priorities for 2025.

As of April 27, 2025, the Federal Trade Commission (FTC) had not filed a petition for a writ of certiorari to appeal the Fifth Circuit’s decision vacating the Combating Auto Retail Scams Trade Regulation Rule (CARS Rule). The ruling, which was issued in response to a petition by the National Automobile Dealers Association and the Texas Automobile Dealers Association, challenged the procedural validity of the FTC’s rulemaking process. The court found that the FTC failed to issue an advance notice of proposed rulemaking as required leading to the vacating of the rule.

Join us for a special crossover episode of The Consumer Finance Podcast and Regulatory Oversight, where Chris Willis, Kim Phan, and Gene Fishel delve into the evolving world of state AI legislation. As AI becomes a pivotal tool in the financial services industry, understanding the implications of new laws is crucial. This episode focuses on Colorado’s comprehensive AI law and its potential influence on other states, exploring key issues such as algorithmic discrimination, privacy, and cybersecurity. Gain insights into best practices for compliance and learn how state attorneys general are stepping up enforcement in the absence of federal action. Don’t miss this informative discussion bridging consumer finance and regulatory oversight.

Yesterday, the U.S. Court of Appeals for the District of Columbia Circuit issued an order temporarily halting the Consumer Financial Protection Bureau’s (CFPB or Bureau) mass layoffs. The court granted an emergency motion to enforce or clarify its previous order, reinstating the preliminary injunction that prevents the CFPB from executing reductions in force (RIFs).

Yesterday, President Donald J. Trump issued an executive order titled “Restoring Equality of Opportunity and Meritocracy.” This order aims to eliminate the use of disparate impact liability in all contexts, emphasizing the importance of treating all citizens equally under the law and promoting a merit-based, colorblind society.

In this episode of The Consumer Finance Podcast, Chris Willis is joined by Troutman Pepper Locke colleagues Lori Sommerfield and Lane Page to dissect two unexpected fair lending developments under the new Trump administration. First, we unpack the Consumer Financial Protection Bureau’s (CFPB) surprising move to vacate its own redlining consent order with Townstone Financial, Inc. We then analyze the Federal Housing Finance Agency’s (FHFA) dramatic policy shift requiring two government sponsored enterprises (GSEs, namely Fannie Mae and Freddie Mac) to terminate special purpose credit programs (SPCPs), as well as the broader implications for mortgage lenders. Join us for the twists and turns of this evolving fair lending regulatory landscape and learn what steps institutions should consider taking to mitigate risks.

At an emergency hearing this morning in National Treasury Employees Union v. Vought, Judge Amy Berman Jackson once again halted the layoffs of over 1,000 employees at the Consumer Financial Protection Bureau (CFPB). The judge emphasized the need for a comprehensive record to determine whether the firings complied with the D.C. Circuit’s order from last week (discussed here).

The Consumer Financial Protection Bureau (CFPB or Bureau) is undergoing significant changes as the Trump administration implements sweeping layoffs just days after revising the Bureau’s regulatory priorities. According to reports, approximately 1,400-1,500 employees have received reduction-in-force notices, leaving the CFPB with just over 200 personnel to carry out its regulatory activities. This drastic reduction raises critical questions about the agency’s ability to effectively focus on its newly outlined priorities for 2025.