News & Analysis as of

Buy Now Pay Later (BNPL) Regulatory Requirements

Troutman Pepper Locke

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

Troutman Pepper Locke on

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

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

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

A&O Shearman on

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

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

Troutman Pepper Locke on

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

Husch Blackwell LLP

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

Husch Blackwell LLP on

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

Mayer Brown

Licensing Link - June 2025

Mayer Brown on

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

Mayer Brown

New York Enacts First-of-Its-Kind Law to License Buy-Now-Pay-Later Lenders

Mayer Brown on

The regulatory environment for “Buy Now, Pay Later” (or “BNPL”) loans is entering a new era. On May 9, 2025, New York enacted legislation that will require providers of BNPL loans to be licensed by the state and adhere to...more

Ballard Spahr LLP

New York Gov. Hochul signs legislation that includes BNPL Licensing Requirements and other Consumer Protection Provisions

Ballard Spahr LLP on

New York Gov. Kathy Hochul has signed legislation that, among other things, imposes new licensing requirements on Buy Now, Pay Later services....more

Hogan Lovells

UK consumer credit reform and buy-now pay-later regulation – May 2025 developments

Hogan Lovells on

On 19 May 2025, HM Treasury released a suite of publications as part of its ongoing efforts to modernise the UK’s consumer credit framework. These include the Consumer Credit Act Reform – Phase 1: May 2025 Consultation, the...more

Sheppard Mullin Richter & Hampton LLP

CFPB Withdraws Dozens of Guidance Documents as Part of Deregulatory Push

On May 12, the CFPB formally withdrew nearly 70 guidance materials—including policy statements, advisory opinions, circulars, and interpretive rules—through a Federal Register notice issued by Acting Director Russell...more

Troutman Pepper Locke

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

Troutman Pepper Locke on

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

Orrick, Herrington & Sutcliffe LLP

CFPB states it will not enforce rule targeting Buy Now, Pay Later loans

On May 6, the CFPB announced it will not prioritize enforcement of its May 2024 interpretive rule which classified Buy Now, Pay Later providers as credit card issuers subject to TILA and Regulation Z (covered by InfoBytes...more

A&O Shearman

UK 2025 Regulatory Initiatives Grid published

A&O Shearman on

The Financial Services Regulatory Initiatives Forum (the Forum) has published the Regulatory Initiatives Forum Grid (the Grid), with the UK Financial Conduct Authority (FCA) also updating its webpage. The previous Grid was...more

A&O Shearman

UK FOS Plans and Budget published for 2025/2026

A&O Shearman on

The UK Financial Ombudsman Service (FOS) has published its plans and budget for 2025/2026, together with an accompanying press release. The FOS notes that there has been more uncertainty than usual over the last year, and...more

Kilpatrick

CFPB Shifts Course on Buy Now, Pay Later: Interpretive Rule Revoked, Legal Challenge Implications

Kilpatrick on

The Consumer Financial Protection Bureau (CFPB) recently announced a significant change in its approach to the burgeoning "buy now, pay later" (BNPL) market. The Bureau has announced plans to revoke its May 2024 interpretive...more

Ballard Spahr LLP

CFPB plans to revoke BNPL interpretive rule

Ballard Spahr LLP on

The CFPB intends to revoke its Buy Now, Pay Later interpretive rule, according to a status report and joint motion to stay filed by the Bureau and the Financial Technology Association (FTA) in a case brought by the FTA...more

A&O Shearman

Buy-now, pay-later: what the future will (and might) hold for the sector

A&O Shearman on

KEY POINTS - - On the face of it buy-now, pay-later (BNPL), as an interest and charge free credit facility, appears low risk but couple its ready availability with the fact that it comes without any of the protections...more

Goodwin

2024 Year in Review: Payday and Small-Dollar Lending

Goodwin on

Welcome to the “Payday and Small-Dollar Lending” chapter of our annual report, Consumer Financial Services: 2024 Year in Review. We expect the level of enforcement and regulatory activity in the payday and short-term...more

Orrick, Herrington & Sutcliffe LLP

CFPB seeks additional time to consider its position on “Buy Now, Pay Later” Interpretive Rule

On February 28, the U.S. District Court for the District of Columbia received a court filing from the CFPB and its Acting Director Russell Vought, indicating they intend to submit a status report by March 31 on whether the...more

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