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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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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.

Do companies that use workplace surveillance tools to make hiring and firing decisions risk violating the Fair Credit Reporting Act (FCRA)? According to the Consumer Financial Protection Bureau (CFPB or Bureau) in a recent comment, the answer to that question is yes. The Bureau’s official comment comes in response to a request for information…

On June 20, the Consumer Financial Protection Bureau’s (CFPB or Bureau) Office of Servicemember Affairs published its Annual Report analyzing complaints submitted by servicemembers, veterans, and their families in 2022. The report found that in 2022, servicemembers submitted over 66,400 complaints, representing a 55% increase from 2021, and a 62% increase from 2020. As in prior years, credit reporting remained the top issue for servicemembers, followed by debt collection and credit cards. Nonetheless, much of the report focused on the rising number of complaints from servicemembers related to payment app fraud and recommended steps the industry can take to address this issue.

Please join Troutman Pepper Partners Chris Willis and James Stevens for a very special announcement about two new great tools for the financial services industry: The Troutman Pepper Financial Services blog and the Troutman Pepper Financial Services app. The blog will provide analysis and commentary on financial services law, regulation, and business, spanning across all areas of law that impact financial services providers. The new app serves as a convenient location to access all of our content, including blogs, articles, podcasts, events, practice area descriptions, and directory of our financial services attorneys. Tune in to hear more about these exciting new ways to stay on top of insights across the entire financial services industry.

The Consumer Financial Protection Bureau (CFPB or Bureau) has signaled that it intends to propose a rule that would allow it to exercise supervisory authority over a greater number of nonbank financial companies that participate in the consumer payments market.

Under the Dodd-Frank Wall Street Reform and Consumer Protection Act (Dodd-Frank), the CFPB has authority…

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. The Consumer Financial Protection Bureau (CFPB or Bureau) issued its massive, highly technical, and complicated Final Rule on March 30, 2023. In this second in a multi-post blog series (the first post is available here), we will take a closer look at the data collection and reporting requirements of the Final Rule.

On June 7, the Federal Trade Commission (FTC) announced a request for information (RFI) to gain additional insight into how it can optimize joint enforcement with state attorneys general (state AGs) to protect consumers from fraud. The announcement signals a growing trend of cooperation between the FTC and state AGs, which we have also seen between the Consumer Financial Protection Bureau (CFPB) and the state regulators.

Please join Troutman Pepper Partners Chris Willis and Jason Cover as they discuss the Consumer Financial Protection Bureau’s (CFPB) recent special edition Supervisory Highlights focused on “junk fees.” Chris and Jason dive into the report and talk about how this fits into the CFPB’s broader initiative on junk fees, what exactly constitutes a junk fee, the types of fees the CFPB identifies as problematic, if this means that creditors can’t charge any of these fees, and steps to take to mitigate risk when imposing fees.