News & Analysis as of

Buy Now Pay Later (BNPL)

Orrick, Herrington & Sutcliffe LLP

CFPB closes investigation into firearm-focused fintech, citing improper targeting

On August 19, the CFPB announced it closed its investigation into a fintech company specializing in buy now, pay later (BNPL) financing for firearms and outdoor goods. The CFPB’s chief legal officer stated that the...more

Sheppard Mullin Richter & Hampton LLP

CFPB Terminates Investigation Into BNPL Firearms Financing Provider, Citing Political Bias

On August 19, 2025, the CFPB announced that it had closed a multi-year investigation into a fintech company offering buy-now, pay-later financing for firearms. The Bureau stated that the matter would not proceed to settlement...more

Troutman Pepper Locke

Point-of-Sale Finance Series: Understanding the Development and Regulation of Buy Now, Pay Later Products — The Consumer Finance...

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In this crossover episode of The Consumer Finance Podcast and Payments Pros, guest host Taylor Gess is joined by Jason Cover and Jeremy Sairsingh to discuss buy now, pay later (BNPL) products as they continue to dive into the...more

Orrick, Herrington & Sutcliffe LLP

Kansas City Fed report highlights growth and risks of BNPL Services

On August 5, the Kansas City Fed released a report that highlighted the rapid growth of “buy now, pay later” (BNPL) services, which let consumers make purchases through short-term installment payments. BNPL products have...more

Mayer Brown

Securitisation Regulatory Update: UK Regulator Consults on Reforms to Deferred Payment Credit (Buy Now Pay Later)

Mayer Brown on

On 14 July 2025, the FSMA (Regulated Activities etc) (Amendment) Order 2025 (the "DPC Legislation") brought unregulated deferred payment credit ("DPC") within the UK Financial Conduct Authority's ("FCA") remit. According to...more

Orrick, Herrington & Sutcliffe LLP

NYDFS issues RFI concerning state Buy-Now-Pay-Later Act

On July 31, NYDFS issued a Request For Information (RFI) seeking responses by August 29 from entities whose activities may be covered by the Buy-Now-Pay-Later (BNPL) Act, as well as from any other interested parties. NYDFS is...more

A&O Shearman

UK FCA consults on BNPL rules for 15 July 2026

A&O Shearman on

The UK Financial Conduct Authority (FCA) has published consultation paper CP25/23, alongside a press release and new webpage, setting out its proposed rules for regulating Deferred Payment Credit (DPC), commonly known as Buy...more

A&O Shearman

UK CBA Panel issues statement on FCA's consultation paper on regulating BNPL products

A&O Shearman on

The Cost Benefit Analysis (CBA) Panel has issued a statement in response to the UK Financial Conduct Authority's (FCA) consultation paper on proposed rules to regulate Deferred Payment Credit (DPC) products, commonly known as...more

Skadden, Arps, Slate, Meagher & Flom LLP

FCA Publishes New Proposals for Buy Now, Pay Later Regulation: One-Year Countdown to July 2026 Implementation

- What is new: The FCA has published Consultation Paper 25/23 proposing new regulations for Buy Now, Pay Later (BNPL) services, now termed deferred-payment credit (DPC), with rules coming into force on 15 July 2026. - Why it...more

A&O Shearman

BNPL UK statutory instrument partially in force

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The UK statutory instrument (The Financial Services and Markets Act 2000 (Regulated Activities etc.) (Amendment) Order 2025) implementing the necessary legislative changes for progressing buy-now, pay-later (BNPL) regulation...more

A&O Shearman

The continuing journey towards buy now, pay later regulation

A&O Shearman on

One could be forgiven, amidst the noise and glamour of the Leeds Reforms and the Mansion House speech, for having missed the snappily titled Financial Services and Markets Act 2000 (Regulated Activities etc.) (Amendment)...more

Hogan Lovells

BNPL: Buy Now, Regulate in 2026 - FCA publishes proposals

Hogan Lovells on

Key takeaways The FCA has published details of the ‘proportionate’, ‘flexible’ and outcomes-focused conduct regime it is proposing for newly regulated BNPL agreements. These include a pragmatic approach to documentation and a...more

Clark Hill PLC

The Learned Concierge - July 2025, Vol. 21

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The Learned Concierge - Welcome to your monthly legal insights on the trends impacting the Retail, Hospitality, and Food & Beverage Industries. Cybersecurity & Privacy - The Monthly Rundown of All Things Cyber, Privacy,...more

Sheppard Mullin Richter & Hampton LLP

HUD Requests Public Input on Buy Now Pay Later Loans and FHA Mortgage Eligibility

On June 24, the Department of Housing and Urban Development (HUD) issued a Request for Information (RFI) to evaluate how Buy Now Pay Later (BNPL) loans may affect FHA-insured mortgage underwriting. The RFI seeks comment on...more

Holland & Knight LLP

Know Now or Pay Later: Navigating New York's Buy-Now-Pay-Later Act

Holland & Knight LLP on

Once hailed as the sleek, interest-free alternative to credit cards, buy-now-pay-later (BNPL) loans have become a defining feature of modern consumer finance. Consumers like them because with just a few clicks, they can...more

Troutman Pepper Locke

Troutman Pepper Locke Weekly Consumer Financial Services Newsletter – July 2025 # 2

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To keep you informed of recent activities, below are several of the most significant federal and state events that have influenced the Consumer Financial Services industry over the past week....more

Ballard Spahr LLP

HUD seeking information about impact Buy Now, Pay Later has on housing expenses

Ballard Spahr LLP on

The Department of Housing and Development is seeking information about the impact that the frequent use of Buy Now, Pay Later (BNPL) products may have on borrowers’ ability to meet housing-related expenses, including rent or...more

Proskauer - Minding Your Business

Buy Now, Pay Later: Regulatory Retreat in Washington, State Regulation on the Rise

Each year, upwards of 100,000 music fans pay up to $599 for the ticket price of weekend-long admission to the Coachella Music and Arts festival outside of Palm Springs, California. In 2025, however, nearly 60% of Coachella’s...more

Orrick, Herrington & Sutcliffe LLP

HUD releases RFI on Buy Now, Pay Later housing products

On June 24, the FHA within HUD issued an RFI seeking public input on the implications of Buy Now, Pay Later (BNPL) lending for housing affordability and stability. Through this RFI, the FHA will seek to better understand how...more

Katten Muchin Rosenman LLP

State AGs and Legislatures Aren’t Taking a Summer Break From Consumer Protection and Financial Services Regulation

As the federal government scales back certain consumer protection and enforcement initiatives, state attorneys general and legislatures are rapidly filling the void — introducing new legislation, launching enforcement actions...more

A&O Shearman

HMT updates BNPL policy for domestic premises suppliers

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HM Treasury has published a policy paper setting out an update to its final position to its 2024 consultation on regulating Buy-Now, Pay-Later (BNPL) products which led to the laying of the draft secondary legislation, The...more

Husch Blackwell LLP

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

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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

Ballard Spahr LLP

CFPB will not issue revised BNPL rule

Ballard Spahr LLP on

Having previously announced that it was withdrawing its Buy Now, Pay Later rule, the CFPB recently said that it does not intend to issue a revised rule....more

Mayer Brown

Licensing Link - June 2025

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Licensing Link is a periodic publication that will keep you informed on hot topics and new developments in state licensing laws, and provide practice tips and primers on important issues related to state licensing across the...more

Hudson Cook, LLP

Consumer Financial Services Bites of the Month - May 2025 - "The CFPB in the End of May"

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In this month's article, we share some of our top "bites" covered during the May 2025 webinar....more

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