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Five Things to Know About the New York Buy-Now-Pay-Later Act

As part of an omnibus 2026 budget bill, New York passed a new law that will broadly govern point-of-sale (POS) installment financing offered to New York residents. The Buy-Now-Pay-Later (BNPL) Act was signed into law in early...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

The OCC Issues Bulletin Addressing Buy Now, Pay Later Lending

What seems to have become a perennial topic for regulators, the Office of the Comptroller of the Currency (OCC) recently released OCC Bulletin 2023-37 to assist national banks and federal savings banks with effectively...more

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