When regulators propose a new rule, financial institutions can often find themselves pushed into a reactionary position, left to deal with consequences that rule makers may not have foreseen. Once a rule hits the books, legal...more
On May 22, 2024, the Consumer Financial Protection Bureau (CFPB) issued an interpretive rule identifying Buy Now, Pay Later Lenders (BNPL Lenders or Lenders) as “card issuers” or “creditors” for the purposes of Regulation Z,...more