News & Analysis as of

Consumer Lenders Buy Now Pay Later (BNPL)

Troutman Pepper Locke

Point-of-Sale Finance Series: Understanding the Development and Regulation of Buy Now, Pay Later Products — The Consumer Finance...

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In this crossover episode of The Consumer Finance Podcast and Payments Pros, guest host Taylor Gess is joined by Jason Cover and Jeremy Sairsingh to discuss buy now, pay later (BNPL) products as they continue to dive into the...more

Mayer Brown

Securitisation Regulatory Update: UK Regulator Consults on Reforms to Deferred Payment Credit (Buy Now Pay Later)

Mayer Brown on

On 14 July 2025, the FSMA (Regulated Activities etc) (Amendment) Order 2025 (the "DPC Legislation") brought unregulated deferred payment credit ("DPC") within the UK Financial Conduct Authority's ("FCA") remit. According to...more

Skadden, Arps, Slate, Meagher & Flom LLP

FCA Publishes New Proposals for Buy Now, Pay Later Regulation: One-Year Countdown to July 2026 Implementation

- What is new: The FCA has published Consultation Paper 25/23 proposing new regulations for Buy Now, Pay Later (BNPL) services, now termed deferred-payment credit (DPC), with rules coming into force on 15 July 2026. - Why it...more

A&O Shearman

BNPL UK statutory instrument partially in force

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The UK statutory instrument (The Financial Services and Markets Act 2000 (Regulated Activities etc.) (Amendment) Order 2025) implementing the necessary legislative changes for progressing buy-now, pay-later (BNPL) regulation...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

Skadden, Arps, Slate, Meagher & Flom LLP

UK Announces New Regime To Regulate ‘Buy-Now, Pay-Later’ Lending Following October 2024 Consultation

In October 2024, HM Treasury (HMT) published a consultation paper amid perceived concerns related to the “buy now, pay later” (BNPL) sector, including uninformed consumer decisions, affordability checks and levels of...more

Latham & Watkins LLP

UK Government Publishes Initial Proposals on CCA Reform

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Government consults on the first stage of reforming the UK consumer credit regime, covering information requirements, sanctions, and criminal offences....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

Venable LLP

Crossing the Pond: What UK Fintechs Taking a Fresh Look at the U.S. Market Need to Know

Venable LLP on

For years, UK-based consumer finance and payments firms have viewed the U.S. regulatory landscape as complex, fragmented, and challenging when it comes to expansion. But 2025 may prove to be a turning point....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

Ballard Spahr LLP

Borrowers with poor credit ratings make up majority of BNPL borrowers

Ballard Spahr LLP on

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

K&L Gates LLP

BNPL Regulation Takes the Final Step in Australia

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On 29 November 2024, the Australian Parliament passed the long-awaited Treasury Laws Amendment (Responsible Buy Now Pay Later and Other Measures) Bill 2024 (Bill)....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

Hudson Cook, LLP

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

Hudson Cook, LLP on

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

Ballard Spahr LLP on

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

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

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

Cooley LLP on

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

Venable LLP on

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

Holland & Knight LLP on

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

Troutman Pepper Locke

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

Troutman Pepper Locke on

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

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