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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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As has been well-documented, the Consumer Financial Protection Bureau (CFPB or Bureau) is navigating a period of significant uncertainty. Just last week, the U.S. Court of Appeals for the District of Columbia vacated a preliminary injunction in the case of National Treasury Employees Union v. CFPB, potentially allowing for substantial layoffs and operational changes within the agency (discussed here). Despite this development, the CFPB briefly released an ambitious rulemaking agenda on the OMB’s Office of Information and Regulatory Affairs website on August 15, which then became inaccessible due to “Site Maintenance.”

On August 8, the Consumer Financial Protection Bureau (CFPB or Bureau) published a series of proposed rules aimed at redefining what constitutes a “larger participant” in several key financial markets. Under § 1024 of the Consumer Financial Protection Act, the Bureau’s supervisory authority extends to “larger participants” offering consumer financial products or services. The proposed rules seek to amend existing thresholds in the consumer reporting, auto financing, consumer debt collection, and international money transfer markets to better align with current market conditions and regulatory priorities. The Bureau is accepting comments on these proposals until September 22, 2025.

On August 15, the U.S. Court of Appeals for the District of Columbia issued a decision in the case of National Treasury Employees Union (NTEU) v. Consumer Financial Protection Bureau (CFPB or Bureau). The appellate court vacated the district court’s preliminary injunction, which had previously restricted the CFPB’s actions to halt the Bureau’s operations and terminate its employees.

In this episode of The Consumer Finance Podcast, Chris Willis is joined by veteran litigators Jason Manning and Carter Nichols to explore litigation implications following the CFPB’s withdrawal of nearly 70 pieces of informal guidance earlier this year. The discussion examines how this significant shift impacts private litigation, particularly in cases where courts previously relied on these guidance documents, opening new avenues for legal arguments and challenges in a landscape where statutory interpretation and legal strategy become paramount with opportunities to redefine precedents and discover uncharted legal territories. The episode underscores the evolving nature of consumer finance litigation and the strategic considerations that come with these regulatory changes.

In this crossover episode of The Consumer Finance Podcast and Payments Pros, Chris Willis, Jason Cover, and Taylor Gess expand on the Point-of-Sale Finance Series to focus on leases and rent-to-own (RTO) models. This conversation spotlights the legal frameworks and best practices for structuring these models and integrating alternative financial options into point-of-sale offerings for goods and services. They also discuss market trends driving the creation of innovative products that are becoming increasingly popular, including virtual RTOs, solar panel leasing, and short-term renewable transactions for ride-share programs.

In this special joint episode of The Consumer Finance Podcast and Payments Pros, Chris Willis, co-leader of Troutman Pepper Locke’s Consumer Financial Services Regulatory Practice, is joined by Keith Barnett and Jason Cover from the Payments Pros podcast, along with Troutman Pepper Locke Consumer Financial Services Partner Mark Furletti. They discuss the future of earned-wage access (EWA) products following the Consumer Financial Protection Bureau’s (CFPB) rescission of previous guidance. The conversation explores the history and evolution of EWA products, initially designed as employer-based solutions to provide employees early access to earned wages without extending credit.

In this special joint episode of The Consumer Finance Podcast and Payments Pros, Chris Willis, co-leader of Troutman Pepper Locke’s Consumer Financial Services Regulatory Practice, is joined by Keith Barnett and Jason Cover from the Payments Pros podcast, along with Troutman Pepper Locke Consumer Financial Services Partner Mark Furletti. They discuss the future of earned-wage access (EWA) products following the Consumer Financial Protection Bureau’s (CFPB) rescission of previous guidance. The conversation explores the history and evolution of EWA products, initially designed as employer-based solutions to provide employees early access to earned wages without extending credit.

In this episode of The Consumer Finance Podcast, Chris Willis is joined by veteran litigators and Troutman Pepper Locke Partners Mary Zinsner and Heryka Knoespel to dissect a groundbreaking Fourth Circuit decision on bank liability in wire transfer fraud cases. The ruling clarifies the actual knowledge standard under the Uniform Commercial Code, rejecting negligence-based liability and safeguarding the speed and efficiency of the banking system. Discover how this decision impacts future litigation and the banking industry’s approach to fraud prevention.

On July 10, the U.S. Department of Housing and Urban Development (HUD) and the Office of Management and Budget (OMB) jointly announced the effective disbandment of the interagency Property Appraisal and Valuation Equity (PAVE) Task Force, a Biden-era initiative aimed at addressing discrimination in real estate appraisals through a whole of federal government approach. The announcement states that this decision to eliminate “the core policies of the PAVE Task Force” is in response to President Trump’s Executive Orders, including Ending Radical and Wasteful Government DEI Programs and Preferencing and Delivering Emergency Price Relief for American Families and Defeating the Cost-of-Living Crisis.

On July 14, the Office of the Comptroller of the Currency (OCC) issued Bulletin 2025-16, announcing the removal of references to disparate impact liability from the “Fair Lending” booklet of the Comptroller’s Handbook and instructing examiners to cease examining banks for disparate impact liability. This change aligns with Executive Order (EO) 14281, issued by President Trump (discussed here), which aims to eliminate the use of disparate impact liability in all contexts at both the federal and state level.