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CFPB’s Latest FAQs Broaden Interpretive Rule for Pay-in-Four BNPL Products

On September 18, the Consumer Financial Protection Bureau (CFPB or Bureau) issued a set of frequently asked questions (FAQs) providing guidance on applying Regulation Z requirements to Pay-in-Four Buy Now, Pay Later (BNPL)...more

CFPB Rules Buy Now, Pay Later Lenders Must Offer Key Credit Card Protections

Yesterday, the Consumer Financial Protection Bureau (CFPB or Bureau) issued an “interpretive rule,” subjecting “Buy Now, Pay Later” (BNPL) transactions to provisions of Regulation Z applicable to “credit cards.” Among other...more

South Carolina Proposes Legislation to Impose Ability-to-Repay Analysis for Installment and Payday Loans

On January 9, a group of five bi-partisan South Carolina Senators introduced Bill 910, which would, among other things, require persons (non-bank lenders) providing “consumer installment loans” or “deferred presentment loans”...more

OCC Issues “Buy Now, Pay Later” Guidance to Banks

This week, the Office of the Comptroller of the Currency (OCC) issued guidance to banks on managing the risks associated with “buy now, pay later” (BNPL) lending. Specifically, the bulletin addresses BNPL loans that are...more

CFPB Issues Analysis on Consumers of Buy Now, Pay Later Products

As we reported here, late last year, the Consumer Financial Protection Bureau (CFPB) signaled that it planned to increase scrutiny of the Buy Now, Pay Later (BNPL) industry and issued its first report about BNPL. Yesterday,...more

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