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Consumer Financial Protection Bureau (CFPB) Buy Now Pay Later (BNPL) Consumer Financial Products

Holland & Knight LLP

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

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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

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

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

Venable LLP

CFPB Withdraws Guidance Documents: A Shift Toward Regulatory Restraint

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The Consumer Financial Protection Bureau (CFPB) is taking a red pen to its own playbook.  In a sweeping move that signals a recalibration of its regulatory posture, the CFPB has announced the withdrawal of 67 guidance...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

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

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

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

Orrick, Herrington & Sutcliffe LLP

CFPB notifies court of its intent to revoke its Buy Now, Pay Later rule

On March 26, the CFPB filed a status report and joint motion to stay proceedings in a case challenging its Buy Now, Pay Later interpretive rule indicating that the Bureau intends to revoke the rule. As previously covered by...more

Goodwin

2024 Year in Review: Payday and Small-Dollar Lending

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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

Hudson Cook, LLP

CFPB Bites of the Month - January 2025 - June in January with the CFPB

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

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

Orrick, Herrington & Sutcliffe LLP

CFPB reports on consumer use of BNPL loan products, calls for further research into BNPL’s impact on consumers’ financial health

On January 13, the CFPB published a report analyzing consumers’ use of Buy Now, Pay Later (BNPL) loan products. This latest report builds on previous CFPB work related to BNPL lending by pairing a matched sample of BNPL...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

CFPB Publishes Supervisory Highlights Focused on Deposits, Small-Dollar Lending, BNPL, and Paycheck Advance Products

During the week of January 6, the CFPB released a “second” Winter 2024 Supervisory Highlights, focused on the agency’s most recent findings in deposits, small dollar lending, buy now, pay later (BNPL), paycheck advance...more

Ballard Spahr LLP

Borrowers with poor credit ratings make up majority of BNPL borrowers

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Borrowers with subprime or deep subprime credit scores make up the majority of Buy Now, Pay Later (BNPL) originations, the CFPB said, in a new report. From 2021 to 2022, borrowers with deep subprime credit scores accounted...more

Troutman Pepper Locke

CFPB Releases Report Highlighting Consumer Use of Buy Now, Pay Later Products

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On January 13, the Consumer Financial Protection Bureau (CFPB or Bureau) released a report providing its analysis of the growth and impact of Buy Now, Pay Later (BNPL) loans in the United States since 2019. BNPL loans,...more

Alston & Bird

Payments Docket – December 2024

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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

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

Ballard Spahr LLP

Financial Technology Association files suit challenging CFPB Buy Now Pay Later (BNPL) interpretive rule

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Alleging that the CFPB rushed to promulgate its interpretive rule, and exceeded its authority in doing so, the Financial Technology Association has filed suit against the bureau in the U.S. District Court for the District of...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

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