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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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Financial services companies are using AI to assist with many business processes, including underwriting decisions, consumer credit approval, servicing and collections, loss mitigation programs, customer interaction on websites and mobile apps via chatbots, and in detecting fraud. In this fourth episode, Stephen Piepgrass and colleagues Chris Willis and Michael Yaghi examine the use and impact of AI in the financial services industry. They discuss the potential risks financial services companies may face with increased reliance on AI, as well as the increased focus on AI by various regulators and state attorneys general.

As discussed here, on March 30, the Consumer Financial Protection Bureau (CFPB) issued its final rule under Section 1071 of the Dodd-Frank Wall Street Reform and Consumer Protection Act (Final Rule). Section 1071 amended the Equal Credit Opportunity Act (ECOA) to impose significant data collection and reporting requirements on small business creditors. On May 12, the CFPB issued a Small Entity Compliance Guide that includes a detailed summary of the Final Rule’s requirements and examples to illustrate some key portions of the Final Rule. For example, illustrations include what constitutes covered originations, what date should be reported for an application, and how a covered entity is to report a response to whether the applicant is a women-owned, minority-owned, and/or LGBTQI+ business if the applicant refuses to respond.

Please join Troutman Pepper Partner Chris Willis and his colleagues Lori Sommerfield and Caleb Rosenberg for the second installment of a special three-part series about the Consumer Financial Protection Bureau’s (CFPB) new small business lending data collection and reporting final rule — the Section 1071 rule. Part 2 takes a deeper dive into the rule’s data collection requirements, including what needs to be collected, when and how, and significant new provisions, dealing with discouraging people from responding to Section 1071 information requests, particularly concerning demographic information.

Please join Troutman Pepper Partners Chris Willis and Kim Phan for an in-depth discussion about the Securities and Exchange Commission’s (SEC’s) recent record retention enforcement actions. Chris and Kim explore the uptick in enforcement actions over the last year, the claims made in these cases, the SEC-imposed requirements and penalties on these companies, what we can expect going forward from the financial services regulators, and what financial institutions should do now to get ahead of these types of enforcement actions.

Citing research that found about half of U.S. adults find it difficult to afford the cost of their healthcare, the Consumer Financial Protection Bureau (CFPB or Bureau) published a report focusing on medical credit cards and loans used to cover basic medical treatment and emergency health care. According to the CFPB, the use of medical…

Please join Troutman Pepper Partner Chris Willis and his colleagues Alan Wingfield, James Kim, and Taylor Gess for the first installment of a special two-part series about the Consumer Financial Protection Bureau’s (CFPB) recent policy statement on abusiveness. In Part 1 the panel discusses the background of the policy statement, the definition of abusiveness, when it exists and when it doesn’t, and practical considerations for compliance.

Please join Troutman Pepper Partner Chris Willis and his colleagues Lori Sommerfield, Addison Morgan, and Josh McBeain for the first installment of a special three-part series about the Consumer Financial Protection Bureau’s (CFPB) new small business lending data collection and reporting final rule — the Section 1071 rule. Part 1 of this special series provides a general overview of the rule, including:

Noting a rise in credit card delinquencies, the Consumer Financial Protection Bureau (CFPB or Bureau) released a new blog post analyzing civil judgments, the final recourse for creditors to collect on unsecured debt. According to the CFPB, civil judgments are “”both common and unevenly distributed.””

Specifically, the CFPB reports that civil judgments are:

  1. Almost twice

…

On April 26, the Texas Bankers Association and Rio Bank, McAllen, Texas filed a complaint in the U.S. District Court for the Southern District of Texas challenging the Consumer Financial Protection Bureau’s (CFPB or Bureau) final rule under § 1071 of the Dodd-Frank Wall Street Reform and Consumer Protection Act (Final Rule). As discussed here, § 1071 amended the Equal Credit Opportunity Act (ECOA) to impose significant data collection and reporting requirements on small business creditors. The plaintiffs rely heavily on the Fifth Circuit’s decision in Community Financial Services Association (CFSA) v CFPB, finding the CFPB’s funding structure unconstitutional and, therefore, rules promulgated by the Bureau invalid. The plaintiffs also argue portions of the Final Rule violate various requirements of the Administrative Procedure Act (APA).