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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.

The Federal Trade Commission (FTC) recently released a Bringing Dark Patterns to Light report, detailing the rise in sophisticated “dark patterns” that the FTC asserts are designed to trick and trap consumers. As the FTC’s latest effort on the subject, the report follows an April 2021 workshop that featured a variety of speakers, including

After analyzing public feedback, as well as information gathered from the five providers of Buy Now, Pay Later (BNPL) products, the Consumer Financial Protection Bureau (CFPB) issued a report, making it clear that the CFPB plans to increase regulation of the BNPL industry.

A form of credit that allows a consumer to split a retail

On August 30, the California Department of Financial Protection and Innovation (CA DFPI) published a notice of rulemaking action, proposing amendments to the Student Loan Servicing Act.

According to the CA DFPI, when the Student Loan Servicing Act first became effective in 2017, student loans contained traditional student loans, defined in the proposed rules as

As we previously posted here, in March, Utah enacted its Commercial Financing Registration and Disclosure Act (CFRDA), requiring commercial financing providers to register with the Utah Department of Financial Institutions (DFI). The process requires registering with the Nationwide Multistate Licensing System and Registry (NMLS), providing certain information about the provider, and disclosing information about

As we previously posted here, in March, Utah enacted its Commercial Financing Registration and Disclosure Act (CFRDA), requiring commercial financing providers to register with the Utah Department of Financial Institutions (DFI). The process requires registering with the Nationwide Multistate Licensing System and Registry (NMLS), providing certain information about the provider, and disclosing information about

Please join Consumer Financial Services Partner Chris Willis and his guests and colleagues Ashley Taylor and Stefanie Jackman in the first episode of a special four-part series about recent developments with the Consumer Financial Protection Bureau (CFPB). In this episode, topics discussed include:

  • Historical background about the cooperation between the CFPB and state attorneys general;
  • Efforts by the CFPB under its new leadership in the current administration directed toward cooperation with state attorneys general;
  • Differences between CFPB and state attorneys general enforcement investigations;
  • Areas where states may take up the CFPB’s invitation to investigate issues under federal law that they might not have done before; and
  • How we think the state attorneys general will find those cases to investigate.

On August 25, the Office of Management and Budget (OMB) directed federal agencies involved in originating consumer and small business loans — including the Small Business Administration, Department of Veterans Affairs, Department of Agriculture, and the Federal Housing Finance Agency — to reduce the impact of medical debt when making underwriting decisions. This instruction aligns

Please join Consumer Financial Services Partner Chris Willis and fellow Partners Lori Sommerfield and Kim Phan, along with special guest Matt Ater from Vispero, as they discuss recent developments in website accessibility governing public accommodations under Title III of the Americans with Disabilities Act (ADA). Topics include:

  • Current litigation trends, including the recent increase in ADA website accessibility lawsuits filed in federal and state courts;
  • Insights into the DOJ’s recent website accessibility guidance and enforcement efforts;
  • Recommendations for companies to achieve website accessibility compliance under the ADA;
  • Technological solutions for website accessibility; and
  • Elements of an effective ADA risk management program.

Banking trade groups are challenging a request for information (RFI) issued by the Consumer Financial Protection Bureau (CFPB) regarding customer service at large financial institutions. In a joint letter dated August 22, the Bank Policy Institute, Consumer Bankers Association, and the American Bankers Association objected to the CFPB’s insinuation that big banks are providing a

Please join Consumer Financial Services Partner Chris Willis and his guests, fellow Partner Alan Wingfield and special guest Tom Kline, as they discuss effective consumer complaint management. They’ll touch on the CFPB’s position on complaint management, the elements and benefits of an effective complaint management system, as well as the potential consequences of not having a complaint management system in place. They conclude the podcast by providing practical tips for handling consumer complaints.