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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 July 7th, the Consumer Financial Protection Bureau (CFPB), U.S. Department of Health and Human Services, and the U.S. Department of Treasury (collectively, the agencies) jointly issued a Request for Information (Request) seeking public comment on medical credit cards, loans, and other financial products used to pay for health care. Specifically, the agencies are interested in information regarding whether these products contribute to health care cost inflation, displace hospital provided financial assistance, lead to inaccurate or inflated medical bills, inflate bills due to financing costs, or otherwise harm patients financially.

Please join Troutman Pepper attorneys Chris Willis, Keith Barnett, Carlin McCrory, and Josh McBeain in announcing the Payment Pros Podcast — our new podcast providing insights for those in the payments law industry. This podcast features analysis and commentary from our attorneys and business leaders, regulatory experts, and stakeholders on the most challenging legal and regulatory concerns confronted by companies and others in the payments industry. From the BSA to EFTs, fintech to regtech, licensure to lending, Nacha to the CFPB, and payment processing to debt collecting, we have you covered!

In this episode of Payments Pros, our hosts Keith Barnett, Carlin McCrory, and Josh McBeain join their colleague Chris Willis to discuss the Consumer Financial Protection Bureau’s (CFPB) larger participant rule for consumer payments mentioned in its 2023 semiannual rulemaking agenda. During this podcast, they examine a myriad of topics concerning this rule, including the following:

The American Association of Bank Directors (AABD) recently published the second edition of its Practical Handbook on Fair Lending for Bank Directors and Executive Officers (the Handbook), updating the first edition of the Handbook issued in 2016. David Baris, President of AABD, and Troutman Pepper partner Lori Sommerfield (two of the original authors) are again co-authors of the Handbook, together with Troutman Pepper partner Chris Willis and associate Sarah Pruett.

As shown by a new report, the Consumer Financial Protection Bureau (CFPB or Bureau) is focusing its fair lending work on mortgage origination and pricing, small business lending, redlining, and the use of artificial intelligence (AI) and machine learning models.

On June 29, the CFPB released its annual Fair Lending Report (Report) to Congress describing its fair lending enforcement and supervisory activities, guidance, and rulemaking for calendar year 2022. The Report satisfies the CFPB’s statutory responsibility to report annually to Congress on public enforcement actions taken pursuant to the Equal Credit Opportunity Act (ECOA).

On June 29, the Federal Financial Institutions Examination Council (FFIEC) announced the availability of data on 2022 mortgage lending transactions reported under the Home Mortgage Disclosure Act (HMDA) by U.S. financial institutions, including banks, savings associations, credit unions, and mortgage companies. The Snapshot National Loan-Level Dataset contains the national HMDA datasets as of May 1, 2023. In March 2023, the FFIEC had made available Loan/Application Registers (LARs) for each HMDA filer of 2022 data, as well as a combined dataset for all filers, modified to protect borrower privacy.

Key observations about the 2022 HMDA data include the following:

Please join Troutman Pepper Partner Chris Willis and colleagues Keith Barnett, Carlin McCrory, and Josh McBeain as they discuss the Consumer Financial Protection Bureau’s (CFPB) larger participant rule for consumer payments mentioned in its 2023 semi-annual rulemaking agenda. During this podcast, they examine a myriad of topics concerning this rule, including the following:

As recently discussed on our podcast here, section 1071 of the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010 (Dodd-Frank Act) amended the Equal Credit Opportunity Act (ECOA) to require lenders to collect information about small business credit applications they receive, including geographic and demographic data concerning the principal owners, lending decisions, and the price of credit. In September 2021, the Consumer Financial Protection Bureau (CFPB or Bureau) issued a proposed rule with more than 900 pages of supplementary material. The Bureau also issued a summary of the proposed rule and a chart of the data points that the rule would require creditors to collect, and it accepted approximately 2,100 comments on the proposal in January 2022. The Bureau then issued the Final Rule on March 30, 2023, with a host of supplementary materials. In this third in a multi-post blog series (first post available here, second here), we will take a closer look at what changed between the proposed rule and the Final Rule.

Please join Troutman Pepper Partners Chris Willis and Misha Tseytlin as they discuss the Supreme Court’s recent decision to review Loper Bright Enterprises v. Sec. of Commerce, which will consider the question of whether to overrule Chevron deference for agency interpretations of statutes. Chris and Misha discuss what may happen if Chevron deference is overruled, either in whole or in part, including how this may affect pending lower court cases, the potential impact on future Administrative Procedure Act cases, and the implications for agency rulemakings that may have relied on Chevron deference when promulgated.

Please join Troutman Pepper Partner Chris Willis and his colleagues Lori Sommerfield and Leigh Poltrock as they discuss HUD’s ever-changing disparate impact rule. Topics include an analysis of the rule’s many versions over the last 10 years, HUD’s reaction to the U.S. Supreme Court’s 2015 Inclusive Communities decision, what we should expect from an enforcement and litigation standpoint, and what industry participants should do in light of these developments.