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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.

In a June 17 blog post, Consumer Financial Protection Bureau (CFPB or Bureau) Director Rohit Chopra announced that the CFPB intends to “move away from highly complicated rules” in favor of “simpler and clearer rules.” As part of this effort, the CFPB will be “dramatically increasing the amount of guidance it is providing to the marketplace” and that it aspires such guidance to be simple and straight forward.

In a blog post released June 15, the Consumer Financial Protection Bureau (CFPB) continued to show its interest in credit reporting by Buy Now, Pay Later (BNPL) lenders. Recognizing the importance of credit reporting to consumers building credit profiles through payment of BNPL obligations, the CFPB encouraged BNPL lenders to report both positive and negative

Please join Troutman Pepper Partner Chris Willis and guests Troutman Pepper Associates Chris Carlson and Susan Nikdel as they discuss the multistate coalition of state attorneys general calling on many of the nation’s largest banks to eliminate overdraft fees. The conversation focuses on what was done, which state attorneys general participated, the current controversy surrounding overdraft fees, and several key takeaways for the industry going forward.

On June 9, California’s Office of Administrative Law approved commercial financing disclosure regulations (Regulations) which require consumer-like disclosures for certain commercial financing products such as small business loans and merchant cash advances. With this final step completed, the Regulations from the Department of Financial Protection and Innovation (DFPI) will become effective on December 9, 2022,

On June 3, the Federal Trade Commission (FTC) published a request for information that could form the basis for a major update of its digital advertising guidance. The FTC’s most recent digital advertising guidance is its 2013 “.com Disclosures – How to Make Effective Disclosures in Digital Advertising” (.com Disclosures Guide). The .com

On May 25, the Consumer Financial Protection Bureau (CFPB or Bureau) published a blog post, examining what it describes as the “practice of suppressing payment data.”

Per the blog post, the CFPB alleges that its research conducted in 2020 “uncovered that only about half of the largest credit card companies contribute data to credit

On May 26, the Consumer Financial Protection Bureau (CFPB or Bureau) announced that federal anti-discrimination law requires companies to explain to applicants the specific reasons for denying an application for credit or taking other adverse actions, even if the creditor is relying on credit models using complex algorithms.

In a corresponding Consumer Financial Protection Circular

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, inviting public comments on the proposed rulemaking. The purpose of the proposed regulations is to implement, interpret, clarify, and make specific, certain sections of the California