Chris Willis, a co-leader of Troutman Pepper Locke’s Consumer Financial Services Regulatory Practice Group, was quoted in the May 27, 2025 Inside Mortgage Finance article, “CFPB Rescinds Rule on State Enforcement of CFPA.”

Chris Willis, partner at the law firm of Troutman Pepper Locke, said the rescission of the rule is unlikely to have much impact on state regulators, who may continue to take the same position as the interpretive rule.

Willis said he believes the CFPB issued the interpretive rule to signal to the states that they have an option to pursue enforcement, rather than trying to set an interpretation of law that a court would agree with.

Willis said states can continue to pursue enforcement under authorities detailed in the interpretive rule but they may be subject to litigation if the target of the enforcement action raises an argument against the interpretation.