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Consumer Financial Products Financial Regulatory Reform Buy Now Pay Later (BNPL)

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

CFPB will not issue revised BNPL rule

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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

Troutman Pepper Locke

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

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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

Ballard Spahr LLP

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

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

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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

Orrick, Herrington & Sutcliffe LLP

New York governor announces financial services updates for state

On May 9, New York Governor Kathy Hochul announced several updates related to financial services for the State of New York. Hochul announced new legislation as part of the FY26 enacted budget to regulate “Buy Now, Pay Later”...more

Ballard Spahr LLP

CFPB won’t prioritize BNPL enforcement

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The CFPB will not make enforcement of its Buy Now, Pay Later rule a priority, according to a recent statement....more

Troutman Pepper Locke

CFPB Shifts Focus Away from Buy Now, Pay Later Loans

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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

Hogan Lovells

FCA Annual Work Programme 2025/26: A work plan reflecting the UK government’s pro-growth mission

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Motor finance, mortgage rule review work and Consumer Duty feature prominently in the work plans for this strategic priority. Firms should note that the FCA includes a warning in relation to the Duty that, where necessary, it...more

Troutman Pepper Locke

Troutman Pepper Locke Weekly Consumer Financial Services Newsletter – April 2025

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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

CFPB plans to revoke BNPL interpretive rule

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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

Sheppard Mullin Richter & Hampton LLP

CFPB to Withdraw BNPL Interpretive Rule Amid Broader Agency Rollback

The CFPB has announced plans to withdraw its May 2024 interpretive rule that subjected buy-now, pay-later (BNPL) products to regulations applicable to credit cards under the Truth in Lending Act (TILA). The move was revealed...more

A&O Shearman

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

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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

Troutman Pepper Locke

Troutman Pepper Locke Weekly Consumer Financial Services Newsletter – January 2025 # 3

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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

Sheppard Mullin Richter & Hampton LLP

Trade Group Challenges CFPB’s Buy Now Pay Later Rule

On October 18, a fintech trade group filed a complaint in a D.C. federal court challenging the CFPB’s interpretive rule on Buy Now, Pay Later (BNPL) products. The rule, released last May, treats BNPL providers as credit card...more

A&O Shearman

Buy Now, Pay Later regulation – the wait is (nearly) over

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It has been a long time in gestation but finally, over three and a half years after the Woolard Review highlighted the potential risks of unregulated, but easily available, interest free credit facilities, we have the...more

Troutman Pepper Locke

Troutman Pepper Weekly Consumer Financial Services Newsletter - September 2024 #4

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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

Troutman Pepper Locke

CFPB’s Latest FAQs Broaden Interpretive Rule for Pay-in-Four BNPL Products

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On September 18, the Consumer Financial Protection Bureau (CFPB or Bureau) issued a set of frequently asked questions (FAQs) providing guidance on applying Regulation Z requirements to Pay-in-Four Buy Now, Pay Later (BNPL)...more

Troutman Pepper Locke

Troutman Pepper Weekly Consumer Financial Services Newsletter - August 2024 # 4

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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

CFPB Proposes Interpretive Rule that EWAs Are Credit; Expedited Funding Fees and Tips May Be Finance Charges under Regulation Z

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On July 18, 2024, the Consumer Financial Protection Bureau (the “CFPB” or “Bureau”) proposed an interpretive rule that states (1) EWA products fall under the definition of “credit” under the Truth in Lending Act (“TILA”) and...more

Troutman Pepper Locke

CFPB's New Interpretive Rule: Buy Now, Pay Later as Credit Cards — The Consumer Finance Podcast and Payments Pros Podcast

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In this special crossover episode of The Consumer Finance Podcast and Payments Pros Podcast, Chris Willis and Josh McBeain interview two colleagues who delve into the Consumer Financial Protection Bureau’s (CFPB) recent...more

Ballard Spahr LLP

Chopra Delivers Testimony to Congress on Semi-Annual Report

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On June 4, 2024, the CFPB issued its Semi-Annual Report to Congress covering the period beginning April 1, 2023 and ending September 30, 2023. On June 12, 2024, CFPB Director Chopra appeared before the Senate Banking...more

Wilson Sonsini Goodrich & Rosati

CFPB’s New Interpretive Rule Takes Aim at BNPL Payment Plans: Practical Takeaways

Providers of Buy Now, Pay Later (BNPL) payment plans are, for purposes of consumer financial protection laws, lenders subject to some of the same regulatory requirements as credit card issuers, under a recent interpretive...more

Skadden, Arps, Slate, Meagher & Flom LLP

CFPB Applies Credit Card Rules to 'Buy Now, Pay Later' Lenders

Following its recent win before the Supreme Court, the Consumer Financial Protection Bureau (CFPB or Bureau) on May 22, 2024, issued an interpretive rule concluding that “Buy Now, Pay Later” (BNPL) loans accessed through a...more

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