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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 June 7, the Federal Trade Commission (FTC) announced a request for information (RFI) to gain additional insight into how it can optimize joint enforcement with state attorneys general (state AGs) to protect consumers from fraud. The announcement signals a growing trend of cooperation between the FTC and state AGs, which we have also seen between the Consumer Financial Protection Bureau (CFPB) and the state regulators.Continue Reading FTC Comment Request Signals Joint Enforcement With State AGs Will Continue Increasing

Financial services companies are using AI to assist with many business processes, including underwriting decisions, consumer credit approval, servicing and collections, loss mitigation programs, customer interaction on websites and mobile apps via chatbots, and in detecting fraud. In this fourth episode, Stephen Piepgrass and colleagues Chris Willis and Michael Yaghi examine the use and impact of AI in the financial services industry. They discuss the potential risks financial services companies may face with increased reliance on AI, as well as the increased focus on AI by various regulators and state attorneys general.Continue Reading AI: Impact and Use in the Financial Services Industry (Part Four)

Artificial intelligence (AI) has captured the imagination and generated excitement with consumers and businesses, but at the same time, developments in AI have also raised public concerns and spawned regulation that sometimes threatens to outpace the technological innovation we are seeing. In this second in our series on AI, Stephen Piepgrass and colleagues Jim Koenig and Chris Willis discuss the background of AI, including the opportunities and associated risks it presents, as well as the emerging global best practices surrounding the collection, use, and sharing of data and its use in AI.Continue Reading AI: Technology, Opportunities, Risks, and Best Practices (Part Two)

Yesterday, 14 Republican attorneys general (AGs) filed an amicus brief in support of a lawsuit brought by the U.S. Chamber of Commerce and other co-plaintiffs against the Consumer Financial Protection Bureau (CFPB or the Bureau), alleging that the Bureau exceeded its statutory authority by amending its examination manual to include discrimination, and in particular disparate

In response to the Fifth Circuit’s ruling in Community Financial Services Association of America, Ltd. v. Consumer Financial Protection Bureau (CFSA) that the Consumer Financial Protection Bureau’s (CFPB) funding mechanism is unconstitutional, West Virginia Attorney General Patrick Morrisey sent a letter on October 24th to the CFPB, calling its continued operations into question and foreshadowing

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.Continue Reading State Attorneys General Call on Financial Giants to Eliminate Overdraft Fees

In a keynote address at the Consumer Federation of America’s 2022 Consumer Assembly, CFPB Deputy Director Zixta Martinez squarely took aim at “rent-a-bank schemes” in some of the first (if not the first) such comments by a senior CFPB official. Historically, the CFPB has confined itself to “true lender” litigation against participants in high-rate

On May 19, the Consumer Financial Protection Bureau (CFPB or Bureau) issued an interpretive rule, describing states’ authorities to pursue companies and individuals that allegedly violate any of the federal consumer financial laws enforced by the CFPB.

CFPB Director Rohit Chopra described this action as “promoting state enforcement, not suffocating it.” It openly invites