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Consumer Financial Products Buy Now Pay Later (BNPL) Lenders

A&O Shearman

UK FCA consults on BNPL rules for 15 July 2026

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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

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

Explore the Impact of Point-of-Sale Finance in Our Upcoming Series — The Consumer Finance Podcast

Troutman Pepper Locke on

In this episode of The Consumer Finance Podcast, Chris Willis is joined by Jason Cover to introduce an upcoming special series focused on point-of-sale finance, a rapidly evolving sector in consumer financial services. This...more

Troutman Pepper Locke

Understanding New York’s New Buy-Now-Pay-Later Law

Troutman Pepper Locke on

New York has included a “Buy-Now-Pay-Later Act” as part of its broader budget legislation for the 2025-2026 fiscal year. Encapsulated in Article 14-B, the Act aims to regulate the burgeoning market of buy-now-pay-later (BNPL)...more

Sheppard Mullin Richter & Hampton LLP

New York Enacts BNPL and Overdraft Fee Restrictions

On May 9, the NYDFS announced that Governor Kathy Hochul signed New York’s FY2026 Budget into law, enacting two major consumer financial protection measures. The budget establishes a licensing and supervision framework for...more

Latham & Watkins LLP

UK Government Sets Out Next Steps on BNPL Regulation

Latham & Watkins LLP on

On 19 May 2025, HM Treasury published its consultation response on the regulation of certain buy-now-pay-later (BNPL) products, setting out its final position, and laid a draft statutory instrument before Parliament to effect...more

Troutman Pepper Locke

CFPB Shifts Focus Away from Buy Now, Pay Later Loans

Troutman Pepper Locke on

The Consumer Financial Protection Bureau (CFPB or Bureau) announced a significant shift in its enforcement priorities, choosing not to prioritize actions related to Buy Now, Pay Later (BNPL) loans under the Truth in Lending...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

Alston & Bird

Payments Docket – December 2024

Alston & Bird on

The latest edition of the Payments Docket, our roundup of key litigation and enforcement involving the payments industry, features why the CFPB’s open banking rule is under fire, a convenience fee that steals your lunch...more

Skadden, Arps, Slate, Meagher & Flom LLP

UK Proposes New Approach To Regulate ‘Buy Now, Pay Later’ Market Amid Rising Consumer Debt Concerns

In the UK, 14 million people used “buy now, pay later” (BNPL) at least once in the six months leading up to January 2023. Frequent users were more than four times as likely as other consumers to have missed a payment on a...more

Hogan Lovells

Buy-Now Pay-Later reform: UK government publishes updated proposals – now over to the FCA

Hogan Lovells on

HM Treasury has published its long-awaited response to the February 2023 consultation on its proposed approach to bringing Buy-Now Pay-Later (BNPL) within the FCA’s regulatory perimeter. The government is clear that “swift...more

Orrick, Herrington & Sutcliffe LLP

New York State floats BNPL legislation in FY 2025 budget

On January 14, New York proposed its FY 2025 budget: Transportation, Economic Development and Environmental Conservation Article VII Bill, which includes an article, cited as the “Buy Now Pay Later Act” (the “Act”). The Act...more

Troutman Pepper Locke

OCC Issues “Buy Now, Pay Later” Guidance to Banks

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This week, the Office of the Comptroller of the Currency (OCC) issued guidance to banks on managing the risks associated with “buy now, pay later” (BNPL) lending. Specifically, the bulletin addresses BNPL loans that are...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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