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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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This article was republished on insideARM on April 22, 2025.

Yesterday, the Consumer Financial Protection Bureau (CFPB or Bureau) released a memo to staff outlining its new supervision and enforcement priorities for 2025.

In this episode of The Consumer Finance Podcast, Chris Willis is joined by colleagues Megan Burns, Jason Manning, and Punit Marwaha to explore the arcane world of reverse mortgages. They provide valuable insights about how these unique financial products work, the regulatory landscape, and the litigation hurdles faced by reverse mortgage servicers. Listen to this episode to hear real-life examples highlighting the complexities reverse mortgage servicers may face when dealing with reverse mortgages, including loan origination requirements, the involvement of the U.S. Department of Housing and Urban Development, Federal Housing Administration guidelines, alleged third-party fraud, and the sensitivity around elderly borrowers.

On April 9, the White House issued a memorandum directing federal executive departments and agencies to repeal regulations deemed unlawful pursuant to certain U.S. Supreme Court decisions. This directive aims to address regulatory barriers that the Trump administration believes hinder economic growth and innovation. The memorandum implements Executive Order 14219, issued on February 19, 2025, which ordered the heads of all federal agencies to identify unlawful and potentially unlawful regulations within 60 days and begin plans to repeal them. Now, the administration is directing agencies to prioritize that review under 10 watershed Supreme Court cases, and to repeal regulations that are considered unlawful under those cases without public notice and comment, if possible.

The Consumer Financial Protection Bureau (CFPB or Bureau) agreed to vacate its controversial credit card late fee rule in a joint motion for entry of consent judgment filed in Chamber of Commerce of the United States of America v. CFPB yesterday. This significant move comes after the U.S. District Court for the Northern District of Texas found that the rule likely violated the Credit Card Accountability and Disclosure Act (CARD Act). The consent judgment marks a pivotal resolution in the case, with the CFPB acknowledging that the rule failed to allow card issuers to impose penalty fees that are “reasonable and proportional” to violations, as required by the CARD Act.

On April 11, the U.S. Court of Appeals for the District of Columbia Circuit issued an order partially staying the district court’s preliminary injunction in the ongoing legal dispute between the National Treasury Employees Union (NTEU) and the Consumer Financial Protection Bureau (CFPB). This decision marks a significant development in the NTEU’s challenge against Acting Director Russell Vought’s actions, which the union claims are unconstitutional and violate the Dodd-Frank Act. The appellate court’s order addresses several key provisions of the district court’s injunction, setting the stage for an expedited appeal process.

On April 9, the House of Representatives passed two Congressional Review Act (CRA) joint resolutions aimed at nullifying certain Consumer Financial Protection Bureau (CFPB) rules finalized in the final days of the Biden-Harris Administration. These resolutions, S.J. Res. 18 and S.J. Res. 28, target rules related to limiting the overdraft fees that may be charged by large financial institutions, and extending supervisory authority over certain providers of digital payments services, respectively. The CRA resolutions are now before President Trump for signature.

As federal agencies pull back on consumer protection regulations under the Trump administration, California is stepping up to fill the void. This shift was forecasted in January, when the Consumer Financial Protection Bureau (CFPB) released a report titled “Strengthening State-Level Consumer Protections” (discussed here), which provided a roadmap for states looking to bolster their consumer protection laws after the anticipated rollback with the new administration.

In this episode of the Consumer Finance Podcast, Chris Willis, co-leader of Troutman Pepper Locke’s Consumer Financial Services Regulatory practice, delves into the current state of machine learning and artificial intelligence (AI) models in underwriting and fraud detection. Chris provides an overview of the regulatory expectations set by the Consumer Financial Protection Bureau, including the historical context and recent developments. He discusses the importance of fair lending considerations, the use of less discriminatory alternative analysis, and the skepticism around certain types of alternative data. Chris also explores the potential impact of state regulations and the need for a long-term approach to fair lending risk. Tune in to stay informed about the evolving landscape of AI and machine learning in consumer finance.

In this episode of The Consumer Finance Podcast, Chris Willis is joined by colleagues Jesse Silverman and James Kim to discuss recent developments in New York’s legislative efforts to strengthen its consumer financial protection laws. They delve into the recently introduced Fair Business Practices Act, which borrows aspects of the Dodd-Frank Act and seeks to expand the New York Attorney General’s powers to mirror those of the Consumer Financial Protection Bureau (CFPB), and its potential impact on businesses and consumers. The discussion highlights the broader trend of states stepping up their consumer protection efforts in response to perceived federal regulatory relaxation. The episode also explores the increasing cooperation and personnel exchange between the CFPB and state regulators, emphasizing the growing influence of state-level enforcement in the consumer financial services landscape. Tune in to understand the implications of these legislative changes and how they might shape the future of consumer financial protection.

On March 28, the Consumer Financial Protection Bureau (CFPB or Bureau) was ordered by the U.S. District Court for the District of Columbia to reinstate its employees and resume its operations. This decision comes after the CFPB allegedly attempted to shut down its activities, leading to the National Treasury Employees Union (NTEU) filing a lawsuit questioning the legality of the shutdown. The court held that the CFPB’s actions to halt its operations and terminate its employees were not consistent with its statutory obligations under Title X of Dodd-Frank. As a result, the court granted a preliminary injunction requiring the CFPB to reverse its shutdown efforts, reinstate its workforce, and continue performing its statutory duties. On March 29, the Bureau filed its notice of appeal of the preliminary injunction.