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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 May 3, the U.S. Court of Appeals for the Fifth Circuit entered an order denying the CFPB’s (CFPB) petition for a panel rehearing and effectively setting the stage for a long-awaited ruling on a preliminary injunction in the ongoing lawsuit challenging the CFPB credit card late fee rule. The petition was filed by the CFPB to reconsider the panel’s order vacating the district court’s order that transferred the case to the U.S. District Court for the District of Columbia and issuing a writ of mandamus directing the district court to reopen the case.

In this episode of The Consumer Finance Podcast, Chris Willis is joined by Troutman Pepper Partner Jeremy Rosenblum and Neil Currie, vice president at the American Arbitration Association (AAA). They discuss the phenomenon of mass arbitration and the recent revisions to the AAA’s rules to address this. The conversation covers the new AAA rules, the fee structure, and the benefits of using AAA over other arbitration administrators. They also discuss strategies for drafting arbitration clauses to avoid the challenges of mass arbitrations. The episode provides valuable insights into the complexities of mass arbitration and offers practical advice for businesses navigating this challenging landscape.

In this episode of The Consumer Finance Podcast, Chris Willis is joined by colleague Jesse Silverman. They discuss the crucial steps fintech firms need to take to establish and maintain successful partnerships with banks. Silverman, with his unique background as a state regulator, CFPB staff member, and fintech executive, provides insights into the preparation, due diligence, and onboarding processes. He emphasizes the importance of understanding the bank’s compliance requirements, having clear policies and procedures, and ensuring a robust information security system. Silverman also discusses the benefits and challenges of using a Banking as a Service (BaaS) partner. The episode provides valuable advice for fintech companies looking to navigate the complexities of partnering with banks in a highly regulated industry.

On April 30, the U.S. Court of Appeals for the Fifth Circuit issued an order vacating the district court’s effective denial of the motion for a preliminary injunction filed by several trade groups, including the U.S. Chamber of Commerce, Fort Worth Chamber of Commerce, Longview Chamber of Commerce, American Bankers Association, Consumer Bankers Association, and Texas Association of Business (collectively, the trade groups). The trade groups are challenging the credit card late fee rule issued by the Consumer Financial Protection Bureau (CFPB) as unconstitutional and violative of the Administrative Procedures Act and seek a preliminary injunction while the case is pending.

In this pivotal episode of The Consumer Finance Podcast, host Chris Willis, alongside colleagues Brooke Conkle and Chris Capurso, explores the Consumer Financial Protection Bureau’s (CFPB) groundbreaking proposal for regular and extensive data collection within the auto finance industry. This episode is part of our special series on auto finance, where we unpack the implications of this initiative, rooted in the authority of Section 1022 of the Dodd-Frank Act, for both the industry and consumers. As the auto finance sector experiences significant growth amid rising prices and rates, we shed light on the CFPB’s strategy to enhance market monitoring and ensure transparency. Join us as we explore the potential impacts of this development, the reactions from major auto finance companies, and what this means for the future of consumer financial services. Don’t miss this insightful discussion that navigates the complexities of regulatory changes and their effects on the auto finance landscape.

In this episode of The Consumer Finance Podcast, Chris Willis is joined by Partners David Anthony and David Dove to discuss the potential implications of the Supreme Court overruling the Chevron case. This case established the principle of deferring to agency interpretations of statutes they administer. While some industry insiders may view the potential overruling as beneficial, the discussion highlights the potential for increased unpredictability and instability. The guests emphasize the importance of vigilance, strategic planning, and the engagement of experienced legal counsel to navigate potential challenges and optimize business opportunities.

Yesterday, the Consumer Financial Protection Bureau (CFPB or Bureau) issued a procedural rule streamlining the designation proceedings for nonbank supervision based on a particular entity posing “risks to consumers.” As discussed in “Our Take” below, the changes are designed to encourage nonbanks to volunteer to be supervised, while making it easier for the CFPB to impose supervisory oversight when companies do not consent.

In this episode of The Consumer Finance Podcast, Chris Willis is joined by David Dove, a partner in Troutman Pepper’s RISE group. They discuss the legal and practical considerations for businesses looking to locate a facility in a new state. David shares his insights on the various incentives available at the federal, state, and local levels, including grants, tax incentives, and economic development programs. He emphasizes the importance of strategic planning, engaging with regulators, and having experienced legal counsel to ensure businesses maximize their opportunities and navigate potential challenges. The discussion provides valuable insights for businesses considering expansion or relocation.

On April 5, the U.S. Court of Appeals for the Fifth Circuit issued an order effectively reversing the district court’s decision to transfer the lawsuit challenging the Consumer Financial Protection Bureau’s (CFPB or Bureau) credit card late fee rule from the Northern District of Texas to the District Court for the District of Columbia (D.D.C), finding that the Texas district court lacked jurisdiction to issue its order because the plaintiffs’ appeal of the effective denial of their motion for preliminary injunction was already pending before the appellate court.