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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.

Late last year, we discussed the Consumer Financial Protection Bureau’s (CFPB or Bureau) proposed rule aimed at supervising larger technology companies offering digital wallets and payment apps. On November 21, the CFPB finalized this rule, which will bring significant changes to the oversight of nonbank digital payment companies. This final rule is set to take effect 30 days after its publication in the Federal Register.

Yesterday, the Board of Governors of the Federal Reserve System (FRB), Consumer Financial Protection Bureau (CFPB), Federal Deposit Insurance Corporation (FDIC), Financial Crimes Enforcement Network (FinCEN), National Credit Union Administration (NCUA), Office of the Comptroller of the Currency (OCC), and state financial regulators issued a joint statement to provide covered financial institutions with strategies and examples of effective risk management and other practices to identify, prevent, and respond to elder financial exploitation. The agencies emphasized that the joint statement does not establish new supervisory expectations or impose new regulatory requirements.

In this episode of The Consumer Finance Podcast, host Chris Willis is joined by Jesse Silverman and Matt Morris to explore the complexities of the CFPB’s nonbank registry rule. This regulation, introduced in 2024, has generated significant confusion due to its intricate requirements. They discuss the rule’s purpose, its impact on nonbank financial services, and the detailed steps companies must take to ensure compliance. Tune in to understand the key definitions, registration deadlines, and the broader implications for the industry.

On December 3, the Consumer Financial Protection Bureau (CFPB or Bureau) issued a proposed rule for public comment aimed at amending Regulation V, which implements the Fair Credit Reporting Act (FCRA). The proposed rule seeks to redefine (and, in some cases, rewrite) key terms and provisions within the FCRA, particularly focusing on the activities of purported “data brokers.”

Join Chris Willis and his colleague Stefanie Jackman as they delve into the recent amendments to New York City’s debt collection rules. In this episode of The Consumer Finance Podcast, they discuss the significant changes, including communication restrictions, validation requirements, and the expanded coverage to include creditors. Learn about the implications for both creditors and debt collectors, the enforcement mechanisms, and the ongoing legal challenges. Stay informed and prepared for the April 1, 2025, enforcement date.

On November 13, the Consumer Financial Protection Bureau (CFPB or Bureau) released a pilot study titled “Matched-Pair Testing in Small Business Lending Markets” highlighting what the CFPB believes were two statistically significant disparities in the treatment of Black and white small business owners seeking loans. First, the secret shopping study indicated that Black entrepreneurs were less encouraged by small business lenders to apply for loans. Specifically, such lenders expressed interest in obtaining loan applications from 40% of white participants, but only 23% of Black participants. Second, the study found that Black participants were more frequently steered toward alternative financing products — such as business credit cards or real estate-secured loans — compared to their white counterparts with similar or weaker business credit profiles. Specifically, non-requested or alternative credit products were discussed with 59% of Black participants, compared to 39% of white participants.

In this episode of The Consumer Finance Podcast, Chris Willis is joined by Partner Kim Phan to discuss the latest cybersecurity guidance from the New York Department of Financial Services (NYDFS) concerning artificial intelligence (AI). Released on October 16, this guidance addresses the growing cybersecurity threats posed by AI and provides insights on how financial institutions can mitigate these risks. Kim and Chris delve into the specifics of the guidance, including the expectations for risk assessments, the importance of monitoring AI usage, and practical steps for enhancing cybersecurity measures. They also highlight the dual perspective of AI risks from both external threat actors and internal vulnerabilities, and discuss the potential benefits of integrating AI into cybersecurity strategies. Tune in to gain a comprehensive understanding of how to navigate these new guidelines and stay ahead in the evolving landscape of cybersecurity.

In this special joint episode of The Consumer Finance Podcast and Moving the Metal, Chris Willis teams up with Brooke Conkle and Chris Capurso, hosts of the Moving the Metal podcast, to discuss the CFPB’s recent supervisory highlights on auto-finance and auto-servicing. Joined by Stefanie Jackman, a partner experienced in auto-finance servicing and collections, the team delves into the CFPB’s findings on issues ranging from repossessions and servicing practices to optional products and credit reporting. They explore the implications of these findings and provide insights into the regulatory landscape, emphasizing the importance of compliance and timely remediation. Tune in for an in-depth analysis of the CFPB’s focus areas and what they mean for the auto-finance industry.

In this special joint episode of The Consumer Finance Podcast and Moving the Metal, Chris Willis teams up with Brooke Conkle and Chris Capurso, hosts of the Moving the Metal podcast, to discuss the CFPB’s recent supervisory highlights on auto-finance and auto-servicing. Joined by Stefanie Jackman, a partner experienced in auto-finance servicing and collections, the team delves into the CFPB’s findings on issues ranging from repossessions and servicing practices to optional products and credit reporting. They explore the implications of these findings and provide insights into the regulatory landscape, emphasizing the importance of compliance and timely remediation. Tune in for an in-depth analysis of the CFPB’s focus areas and what they mean for the auto-finance industry.

In a significant development, the Consumer Financial Protection Bureau (CFPB or Bureau) has finally reached a settlement with Townstone Financial, Inc. (Townstone) in the first redlining case brought against a nonbank mortgage lender and broker. This settlement follows the Seventh Circuit Court of Appeals’ pivotal decision in favor of the CFPB that expanded the Equal Credit Opportunity Act (ECOA) to include protections for prospective applicants who may be discouraged from applying for credit. The settlement marks a resolution of protracted litigation that began in 2020 when the CFPB sued Townstone by accusing the company of redlining practices.