In this episode of The Consumer Finance Podcast, host Chris Willis is joined by colleague Kim Phan to break down the proposed regulations recently released by the Colorado attorney general (AG) under the Automated Decision-Making Technology (ADMT) Act, Colorado’s newly amended AI statute, and explain why the financial services industry needs to engage before these rules are finalized.

https://the-consumer-finance-podcast.simplecast.com/episodes/colorados-admt-act-proposed-regulations-unpacking-the-confusion-and-compliance-challenges-for-financial-services

Chris and Kim walk through several provisions that diverge sharply from what industry had hoped for after the statute’s May 2026 rewrite, including a narrow definition of “financial or lending service” that leaves debt collection and insurance in uncertain territory and a meaningful human review requirement that effectively demands full judgmental re-underwriting of automated credit decisions. The hosts also highlight consumer rights provisions that would require disclosure of every data input and score used in an ADMT decision, thus creating significant trade secret exposure and fraud risk with little identifiable consumer benefit.

The episode closes with the rulemaking timeline: public comments are due October 5, a hearing is scheduled for October 26, and the AG must finalize rules by January 1, 2027.


Transcript: Colorado’s ADMT Act Proposed Regulations: Unpacking the Confusion and Compliance Challenges for Financial Services (PDF)

Photo of Chris Willis Chris Willis

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…

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.

Chris also leverages insights from his litigation and enforcement experience to help clients design new products and processes, including machine learning marketing, fraud prevention and underwriting models, product structure, advertising, online application flows, underwriting, and collection and loss mitigation strategies.

Chris brings a highly practical focus to his legal advice, informed by balancing a deep understanding of the business of consumer finance and the practical priorities of federal and state regulatory agencies.

Chris speaks frequently at conferences across the country on consumer financial services law and has been featured in numerous articles in publications such as the Wall Street Journal, the New York Times, the Washington Post, American Banker, National Law Journal, BNA Bloomberg, and Bank Safety and Soundness Advisor.

Photo of Kim Phan Kim Phan

Kim is a privacy and data security lawyer who counsels companies in federal and state privacy and data security statutes and regulations. Her work encompasses strategic planning and guidance for companies to incorporate privacy and data security considerations throughout product development, marketing, and

…

Kim is a privacy and data security lawyer who counsels companies in federal and state privacy and data security statutes and regulations. Her work encompasses strategic planning and guidance for companies to incorporate privacy and data security considerations throughout product development, marketing, and implementation.