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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.

On January 3, the Consumer Financial Protection Bureau (CFPB) released its annual report detailing what it characterized as “improvements and deficiencies” in the nationwide consumer reporting agencies’ (NCRAs) responses to complaints. The Fair Credit Reporting Act (FCRA) requires the CFPB to submit this annual report to Congress. While in last year’s report, the CFPB said

As discussed here, on May 20, California’s Department of Financial Protection and Innovation (DFPI or Department) announced that it had filed a Notice of Proposed Rulemaking with the Office of Administrative Law. The purpose of the proposed regulations is to make explicit what it means to provide a timely response to consumer complaints. Covered

On December 6, during the 2022 Interagency Fair Lending Webinar, David Evans, a senior fair lending specialist with the Federal Deposit Insurance Corporation (FDIC), discussed some of the specific discrimination issues identified during FDIC examinations that were ultimately referred to the Department of Justice (DOJ) as potential fair lending violations. One area highlighted in the

As a further reflection of its recent emphasis on “repeat offenders,” on December 12, the Consumer Financial Protection Bureau (CFPB) published a proposed rule with request for public comment that would require certain nonbank covered entities (with exclusions for insured depository institutions and credit unions) that are under certain final public orders issued by a

Please join Consumer Financial Services Partner Chris Willis and his colleagues Jeremy Rosenblum and Tony Kaye as they discuss the phenomenon of mass arbitrations, which pose increasing risk to the consumer finance industry. The partners use their knowledge to explain what mass arbitration is and describe prophylactic measures companies should take.

The Consumer Financial Protection Bureau (CFPB) issued a decision denying Nexo Financial, LLC’s petition to modify a civil investigation demand (CID) originally served on the company on December 1, 2021. At that time, Nexo Financial and its affiliates advertised a range of products, including interest-accruing accounts and lines of credit. In its petition, Nexo Financial

As discussed here, on November 18, the Biden administration filed an application with the U.S. Supreme Court to vacate the Eighth Circuit injunction temporarily pausing the administration’s student loan forgiveness program. In its application, the administration requested that the Court either vacate the injunction, or, in the alternative, to construe the application as a

As discussed here, last month, the Eighth Circuit granted an emergency motion by Republican officials in six states to temporarily pause the Biden administration’s student loan forgiveness program while they appeal the dismissal of their challenge by a Missouri federal judge, who found that they do not have standing to sue. On November 18