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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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On October 6, the New York State Department of Financial Services (NYDFS) announced a consent order with Rhinebeck Bank (Rhinebeck) to resolve allegations that, in violation of New York Executive Law Section 296-a, the bank instituted discretionary dealer markup policies that resulted in a disparate impact that negatively affected members of minority groups.

In addition…

Please join Consumer Financial Services Partner Chris Willis and his colleague Partner Misha Tseytlin to discuss the Fifth Circuit’s decision in Community Financial Services Association of America, Ltd. v. Consumer Financial Protection Bureau, what may happen next and when, and the ruling’s practical impact on the consumer finance industry. As noted in our October 20 blog about the CFSA case, a Fifth Circuit panel found the funding mechanism for the CFPB to be unconstitutional.

In a major decision released October 19, a three-judge panel of the Fifth Circuit Court of Appeals found the funding mechanism for the Consumer Financial Protection Bureau (CFPB or Bureau) to be unconstitutional. Specifically, the court in Community Financial Services Association of America, Ltd. v. Consumer Financial Protection Bureau held the CFPB’s funding violates the…

Please join Consumer Financial Services Partner Chris Willis and his colleagues and fellow Partners Mary Zinsner and Susan Flint as they discuss the current landscape of wire fraud scams in the financial services industry. Topics include:

  • Wire fraud scams, such as Business Email Compromise (BEC) fraud, and the potential liability of banks;
  • How banks should analyze wire fraud claims in the pre-litigation stage;
  • How courts are ruling on the issues;
  • Responsibilities of nonbank parties to the wire; and
  • Tips for bank in-house counsel in handling wire fraud transfer situations.

On October 13, the Consumer Financial Protection Bureau, the Federal Reserve Board, and the Office of the Comptroller of the Currency announced increased dollar thresholds used to determine whether certain consumer credit and lease transactions in 2023 are exempt from Regulation Z (Truth in Lending) and Regulation M (Consumer Leasing).

Specifically, based on the annual…

Please join Consumer Financial Services Partner Chris Willis and his colleagues Ron Raether and Kim Phan, partners in our Privacy + Cyber Practice Group, as they discuss recent privacy and data security updates in the consumer financial services industry. Topics include:

  • The CFPB’s and FTC’s regulatory stance on privacy and data security issues;
  • The current landscape of privacy legislation; and
  • Emerging trends in privacy and data security litigation, including the status of litigation under the California Consumer Privacy Act, and how businesses can protect themselves going forward.

Please join Troutman Pepper Partner Chris Willis and his guest and fellow Partner Glen Trudel as they discuss credit card rewards and loyalty programs and the co-brand relationship. Topics include:

  • The importance of the co-brand credit card pairing;
  • Issues, concerns, or risks that both the merchant and the card issuer encounter in co-brand rewards programs; and
  • Current trends in the marketplace for credit card rewards programs.

Banking groups are taking issue with a report by Senator Elizabeth Warren (D-MA) regarding the prevalence of fraud on Zelle, the popular peer-to-peer (P2P) payment service. In an October 3 joint statement, the Consumer Bankers Association, American Bankers Association, Bank Policy Institute, and The Clearing House expressed their collective disagreement with the report’s conclusions…

On September 29, the Consumer Financial Protection Bureau (CFPB or Bureau) released a special edition of its Supervisory Highlights, focusing on student loan servicing. The report contained findings on federal student loan servicing that echo many recent public comments by the Bureau, but more notably, this edition of Supervisory Highlights also focused heavily on…

On September 28, the U.S. Chamber of Commerce (Chamber), together with the Longview Chamber of Commerce, American Bankers Association, Consumer Bankers Association, Independent Bankers Association of Texas, Texas Association of Business, and Texas Bankers Association, filed a lawsuit in the Eastern District of Texas against the Consumer Financial Protection Bureau (CFPB) to prevent the amendment…