Photo of Chris Willis

Chris Willis

Subscribe to Chris Willis's Posts

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.

Follow:Read more about Chris WillisChris's Linkedin Profile

In this special crossover episode of Payments Pros and The Consumer Finance podcasts, Carlin McCrory, Keith Barnett, and Chris Willis explore the federal government’s increasing attention to “debanking” and what it means for payment processors, money transmitters, banks, and other financial services providers. They discuss recent federal initiatives and agency activity that have heightened scrutiny of decisions to onboard, maintain, or terminate customers and merchants, particularly where those decisions may be perceived as based on political or religious viewpoints.

In this episode of The Consumer Finance Podcast, Chris Willis, Lori Sommerfield, Taylor Gess, and Lane Page discuss the CFPB’s sweeping final amendments to Subpart A of Regulation B. The group unpacks the elimination of the disparate impact legal theory from ECOA, the narrowing of the discouragement standard (including what it means for targeted advertising), and the significant new limits on special purpose credit programs (SPCPs). They also explore expected litigation challenges, the continuing role of the Fair Housing Act and state laws in bringing cases under the disparate impact theory, and the practical steps lenders should be taking now to reassess fair lending testing, SPCP design, and redlining risk in light of the final rule.

On February 23, the New York Department of Financial Services (DFS) issued a proposed new Part 423 to Title 3 of the NYCRR to implement New York Banking Law Article 14‑B for Buy-Now-Pay-Later (BNPL) lenders. The proposal would move BNPL firmly into New York’s credit system, imposing licensing, supervision, disclosure, data privacy, and underwriting requirements on both interest‑free and interest‑bearing BNPL products offered to New York consumers. If adopted, the rule would take effect 180 days after the notice of adoption is published in the State Register, with a short transitional period for existing BNPL providers. DFS is accepting pre-proposal comments through March 5, 2026, after which the proposed rule will be published in the New York state register for a formal 60-day comment period.

In this special crossover episode of Regulatory Oversight and The Consumer Finance Podcast, Chris Willis is joined by colleagues Lori Sommerfield and Matthew Berns to discuss New Jersey’s sweeping new disparate impact regulations under the Law Against Discrimination. They break down one of the most comprehensive state-level disparate impact rules in the U.S., the contrasts with traditional federal standards, and implications for enforcement in financial services. The discussion dives into credit scores, underwriting models, AI and automated decision-making tools, and the difference between New Jersey’s approach and the Trump administration’s effort to scale back disparate impact at the federal level, offering practical takeaways for lenders and other covered entities navigating this shifting landscape.

On December 19, 2025, New York Governor Kathy Hochul signed into law the Fostering Affordability and Integrity through Reasonable (FAIR) Business Practices Act. The FAIR Act, which was proposed by Attorney General (AG) Tish James, represents the first major update to the state’s primary consumer protection law in 45 years and significantly broadens the statute’s reach.

On December 17, New Jersey announced its adoption of what its Attorney General is calling the “most comprehensive state-level disparate impact regulations in the country.” Effective December 15, 2025, the Division on Civil Rights’ (DCR) new rules under the New Jersey Law Against Discrimination (LAD) codify guidance on disparate impact discrimination across housing, lending, employment, places of public accommodation, and contracting.

In this crossover episode of The Consumer Finance Podcast and Regulatory Oversight, Chris Willis is joined by Joseph DeFazio, Bill Foley, and Michael Yaghi to discuss the implications of New York’s FAIR Act, a significant amendment to the state’s UDAAP statute. The FAIR Act aims to broaden consumer protection by lowering the threshold for legal action against unfair and abusive business practices. With expanded enforcement powers for the state, this legislation could dramatically increase litigation risks for financial services companies operating in New York if the governor signs the bill. Tune in to understand how this legislative shift might affect the industry and what steps businesses can take to prepare.

On June 25, the California Department of Financial Protection and Innovation (DFPI) entered a consent order with Coinme, Inc., a cryptocurrency “ATM” operator, for noncompliance with the California’s Consumer Financial Protection Law (CCFPL) and Digital Financial Assets Law (DFAL). The consent order marks a significant milestone in California’s regulatory efforts because it represents the conclusion of the agency’s first enforcement action under the DFAL.

New York City Comptroller Brad Lander released a report titled “Standing Up for New York Consumers – How New York State and New York City can Strengthen Consumer Financial Protection in the Trump Era,” which called for the strengthening of local consumer financial protections in response to the Trump administration’s recent actions to reduce the regulatory footprint of the Consumer Financial Protection Bureau (CFPB or Bureau).

In this crossover episode of The Consumer Finance Podcast and Regulatory Oversight, Chris Willis, Kim Phan, and Stephen Piepgrass provide insights on a new joint privacy task force among several state AGs, known as the Consortium of Privacy Regulators. The consortium recently outlined goals to share state resources and align enforcement priorities regarding consumer harm and privacy rights. In response to an anticipated shift of regulatory scrutiny from federal agencies to state leaders, this episode focuses on specific steps financial services companies should consider when dealing with consumer privacy, data, complaints, and inquiries to ensure compliance and mitigate potential investigations and enforcement actions.