News & Analysis as of

Buy Now Pay Later (BNPL) Risk Management

Hudson Cook, LLP

CFPB Bites of the Month - 2024 Annual Review - Fintech

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In this article, we share a timeline of our monthly "bites" for 2024 applicable to companies in FinTech. The Consumer Financial Protection Bureau was on a tear in the months leading up to the election and the inauguration of...more

Hudson Cook, LLP

Pay Now or Pay Later, But Paying Later May Cost a Whole Lot More

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The Consumer Financial Protection Bureau has long required that an institution within the scope of its supervision or enforcement authority, including both depository institutions like banks and non-depository consumer...more

Jenner & Block

Client Alert: Buy Now, Pay Later: A Roadmap for Providers as Regulators Continue to Increase Scrutiny

Jenner & Block on

Point-of-sale financing arrangements payable in four or fewer interest-free installments, known as buy now, pay later (BNPL) arrangements, have soared since their initial breakthrough during the pandemic. Unlike conventional...more

American Conference Institute (ACI)

[Event] 8th Forum on FinTech & Emerging Payment Systems - April 9th - 10th, New York, NY

ACI’s 8th Annual Legal, Regulatory, and Compliance Forum on Fintech & Emerging Payment Systems will provide in-depth guidance on the latest regulatory developments at the Federal and State Level that you need to be aware of....more

Spilman Thomas & Battle, PLLC

Promissory Notes - Banking & Finance Insights: V 4, Issue 1, January 2024

OCC Issues Guidance on ‘Buy Now, Pay Later’ Lending - “The guidance notes that banks should maintain underwriting, repayment terms, pricing, and safeguards that minimize adverse customer outcomes and should ensure that...more

Nutter McClennen & Fish LLP

Nutter Bank Report: December 2023

A recent OCC report identified key issues facing the federal banking system, including increasing credit risk due to higher interest rates, increasing risk in commercial real estate lending, prolonged inflation, declining...more

Cooley LLP

OCC Issues Risk Management Guidance for BNPL Lending

Cooley LLP on

On December 6, 2023, the Office of the Comptroller of the Currency (OCC) issued a bulletin that provides guidance to banks on managing risks associated with certain “buy now, pay later” (BNPL) loans. While the OCC notes that...more

Husch Blackwell LLP

The OCC Issues Bulletin Addressing Buy Now, Pay Later Lending

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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

Ballard Spahr LLP

OCC issues guidance on managing risks associated with “buy now, pay later” lending

Ballard Spahr LLP on

The Office of the Comptroller of the Currency (OCC) has issued a bulletin (2023-37) that provides guidance on managing risks associated with “buy now, pay later” (BNPL) lending.  The BNPL loans addressed in the bulletin are...more

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