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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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Yesterday, the U.S. Department of Justice (DOJ) notified the U.S. District Court for the District of Columbia and the D.C. Circuit in the matter of National Treasury Employees Union v. Vought that the Consumer Financial Protection Bureau (CFPB or Bureau) anticipates exhausting its currently available funds in early 2026. The filing attaches a November 7 opinion from the Office of Legal Counsel (OLC) to Acting Director Vought concluding that the CFPB’s statutory funding stream — quarterly transfers from the “combined earnings of the Federal Reserve System” under 12 U.S.C. § 5497(a)(1) — is unavailable while the Federal Reserve operates at a loss. The Bureau expects to continue operating, including in compliance with an existing district court injunction, through at least December 31, 2025, but absent congressional action may face a funding lapse thereafter, which would trigger Antideficiency Act constraints.

On October 29, the Consumer Financial Protection Bureau (CFPB or Bureau) officially rescinded its rule requiring nonbank entities to register certain agency and court orders with the Bureau. This decision follows a proposal made earlier this year (discussed here), which highlighted concerns about the regulatory burden and costs imposed on nonbank entities, which could ultimately affect consumers.

In this episode of The Consumer Finance Podcast, Chris Willis is joined by colleagues Jason Manning and Carter Nichols to explore the intricacies of the Servicemembers Civil Relief Act (SCRA). As the current administration emphasizes the protection of servicemembers, understanding the SCRA’s provisions is more crucial than ever. The discussion covers the array of legal protections offered to active duty military members, reservists, and National Guard members, including interest rate caps, eviction protections, and lease terminations. The episode also delves into the complexities of active duty status and the differences between the SCRA and the Military Lending Act. With a surge in litigation and regulatory scrutiny, this episode provides timely insights for financial institutions navigating compliance and litigation risks. Tune in to grasp the nuances of these critical statutes and their implications for the consumer finance industry.

In this crossover episode of Payments Pros and The Consumer Finance Podcast, Chris Willis, Jason Cover, and Taylor Gess discuss licensed lending and bank model lending programs. This conversation dives into the benefits, challenges, and regulatory landscapes that shape these popular lending models for financial institutions and fintechs. Consumer finance providers will gain valuable insights on structuring successful lending partnerships in today’s complex environment.

On October 28, the Consumer Financial Protection Bureau (CFPB or Bureau) issued a new interpretive rule replacing its 2022 interpretive rule (withdrawn in May 2025) concerning the scope of preemption under the Fair Credit Reporting Act (FCRA). This new interpretive rule clarifies that the FCRA broadly preempts state laws related to consumer reporting, reinforcing Congress’s intent to establish national standards when information is used to determine a consumer’s eligibility for credit, insurance, employment and the like. This move replaces the previous rule, which was criticized for its potential to create regulatory confusion.

In this episode of The Consumer Finance Podcast, Chris Willis is joined by Lori Sommerfield and James Stevens to delve into the implications of President Trump’s Executive Order 14331, “Guaranteeing Fair Banking for All Americans.” This order aims to eliminate politicized or unlawful de-banking practices by prohibiting financial institutions from denying access to banking services based on political, religious, or ideological beliefs. The trio discusses the historical context of de-banking, tracing its roots back to the Obama-era Operation Choke Point, and explores the current regulatory landscape shaped by the executive order. They analyze the directives issued to federal agencies, including the Small Business Administration and the Office of the Comptroller of the Currency, and the potential risks and challenges facing financial institutions. Tune in to understand how this regulatory push will likely impact the banking industry and what steps institutions can take now to mitigate risks.

On October 2, the Consumer Financial Protection Bureau (CFPB or Bureau) published a final rule in the Federal Register, officially extending compliance dates for its 2023 small business lending data collection and reporting rule under the Equal Credit Opportunity Act (ECOA) and Regulation B, which implements Section 1071 of the Dodd-Frank Act. The final rule replaces an interim rule released in June 2025 that pushed back compliance deadlines. This extension was issued by the CFPB in response to ongoing litigation by both industry and consumer advocacy groups, as well as court orders, to create a uniform timeline for financial institutions to comply with data collection and reporting requirements for women-owned, minority-owned, and small businesses.

In this crossover episode of Payments Pros and The Consumer Finance Podcast, Carlin McCrory is joined by colleague Kim Phan to discuss the Consumer Financial Protection Bureau’s (CFPB) recent developments regarding Section 1033 of the Consumer Financial Protection Act (CFPA). This summer, the CFPB initiated a new rulemaking process, inviting industry comments on its final rule concerning personal financial data rights. With a deadline of October 21 for public comments, industry participants are encouraged to weigh in on access to consumer financial information.

In this crossover episode of The Consumer Finance Podcast and Regulatory Oversight, Chris Willis is joined by Joseph DeFazio, Bill Foley, and Michael Yaghi to discuss the implications of New York’s FAIR Act, a significant amendment to the state’s UDAAP statute. The FAIR Act aims to broaden consumer protection by lowering the threshold for legal action against unfair and abusive business practices. With expanded enforcement powers for the state, this legislation could dramatically increase litigation risks for financial services companies operating in New York if the governor signs the bill. Tune in to understand how this legislative shift might affect the industry and what steps businesses can take to prepare.

Recently, the U.S. Department of Housing and Urban Development (HUD) issued two memoranda that clarify HUD’s role in enforcing the Fair Housing Act (FHA), explain how future enforcement efforts will proceed, and officially rescind several guidance documents related to disparate impact and redlining, among other topics.