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The State of the CFPB During a Fraught Transition Period: Part II

It has been a little over two months since President Donald Trump returned to office, and since then, the Consumer Financial Protection Bureau (CFPB) has been in flux—to put it mildly. As of this writing, it is unclear...more

The CFPB Determines "Buy Now, Pay Later" Providers Are Card Issuers under Regulation Z

Yesterday, the Consumer Financial Protection Bureau (CFPB) released an interpretive rule stating that “Buy Now, Pay Later” (BNPL) providers are “card issuers” and “creditors” under the federal Truth in Lending Act (TILA) and...more

A Closer Look at New York's Proposed Abusiveness Prohibition

In January, New York Governor Kathy Hochul introduced a budget bill that proposed the headline-grabbing Buy Now Pay Later licensing regime. Less attention has been given to another proposed provision: adding a prohibition on...more

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