News & Analysis as of

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

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

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

Kilpatrick

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

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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

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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

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

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

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

Ankura

The CFPB Sets Its Sights on Buy Now, Pay Later Lenders in New Interpretive Rule

Ankura on

On May 22, 2024, the Consumer Financial Protection Bureau (CFPB) issued an interpretive rule identifying Buy Now, Pay Later Lenders (BNPL Lenders or Lenders) as “card issuers” or “creditors” for the purposes of Regulation Z,...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

Ballard Spahr LLP

Consumer Finance Monitor Podcast Episode: How the CFPB Is Using Interpretive Rules to Expand Regulatory Requirements for...

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Today’s podcast, which repurposes a recent webinar, is the conclusion of a two-part examination of the CFPB’s use of a proposed interpretive rule, rather than a legislative rule, to expand regulatory requirements for earned...more

Troutman Pepper Locke

Navigating the CFPB's Controversial Interpretive Rule on BNPL Products — The Consumer Finance Podcast

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In this episode of The Consumer Finance Podcast, Chris Willis is joined by Partners Mark Furletti and Jason Cover to delve into the CFPB's recent interpretive rule that classifies buy now, pay later (BNPL) products as credit...more

Cooley LLP

CFPB Doubles Down on Buy Now, Pay Later Interpretive Rule in New FAQs

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On September 18, 2024, the Consumer Financial Protection Bureau (CFPB) published a compliance aid to its May 2024 interpretive rule, which classifies certain providers of buy now, pay later (BNPL) products as card issuers...more

Venable LLP

CFPB Issues FAQs: Expands Interpretive Rule for BNPL Products

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On September 18, the CFPB issued a set of Frequently Asked Questions (FAQs) related to Buy Now, Pay Later (BNPL) products. These FAQs follow the CFPB's release of the 2024 BNPL Interpretive Rule (Interpretive Rule), which...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

Orrick, Herrington & Sutcliffe LLP

CFPB publishes BNPL FAQs

On September 18, the CFPB issued Frequently Asked Questions (FAQ) guidance on Buy Now, Pay Later (BNPL) products. The FAQs are organized into three sections: (i) a general description of BNPL products and “Pay-in-Four” BNPL...more

Holland & Knight LLP

CFPB Keeps to Its Word by Issuing Additional Buy Now, Pay Later Guidance

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purred by increased online and mobile app shopping during the COVID-19 pandemic, the Buy Now, Pay Later (BNPL) market has experienced higher growth and popularity as an innovative consumer finance offering, particularly for...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

Hudson Cook, LLP

CFPB Bites of the Month - August 2024 - All That's Left of the CFPB's Summer Sky

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In this month's article, we share some of our top "bites" for the prior and current month covered during the August 2024 webinar....more

Cadwalader, Wickersham & Taft LLP

CFPB Updates on Buy Now, Pay Later Lending

On August 16th, the Consumer Financial Protection Bureau ("CFPB") Director, Rohit Chopra, published a blog post entitled “What Buy Now, Pay Later lenders are doing to be upfront with borrowers” that follows up on its proposed...more

Sheppard Mullin Richter & Hampton LLP

Congressional Measure Aims to Undo Recent CFPB Buy Now Pay Later Guidance

On August 2, members of U.S. House of Representatives introduced H.J. Res. 195, a joint resolution providing for congressional disapproval under the Congressional Review Act (CRA) of recent CFPB guidance (previously discussed...more

Wiley Rein LLP

Wiley Consumer Protection Download (July 30, 2024)

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Welcome to Wiley’s update on recent developments and what’s next in consumer protection at the Consumer Financial Protection Bureau (CFPB) and Federal Trade Commission (FTC). In this newsletter, we analyze recent regulatory...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

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