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Hogan Lovells

Buy-Now Pay-Later regulation: Government confirms final position

Hogan Lovells on

HM Treasury has confirmed its approach to the regulation of Buy-Now Pay-Later (BNPL) lending in its response to the October 2024 consultation. On 19 May 2025, Government also laid draft legislation before Parliament. Given...more

Hogan Lovells

UK consumer credit reform and buy-now pay-later regulation – May 2025 developments

Hogan Lovells on

On 19 May 2025, HM Treasury released a suite of publications as part of its ongoing efforts to modernise the UK’s consumer credit framework. These include the Consumer Credit Act Reform – Phase 1: May 2025 Consultation, the...more

Skadden, Arps, Slate, Meagher & Flom LLP

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

Skadden, Arps, Slate, Meagher & Flom LLP on

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

Sheppard Mullin Richter & Hampton LLP

CFPB Interpretive Rule Holds That BNPL Lenders Are Credit Card Providers

Sheppard Mullin Richter & Hampton LLP on

On May 22, the CFPB announced an interpretive rule confirming that Buy Now, Pay Later (BNPL) lenders qualify as credit card providers under the Truth in Lending Act, Regulation Z and are required to provide consumers legal...more

Orrick, Herrington & Sutcliffe LLP

New York State floats BNPL legislation in FY 2025 budget

Orrick, Herrington & Sutcliffe LLP on

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

Troutman Pepper Locke on

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

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