News & Analysis as of

Loans Buy Now Pay Later (BNPL) Regulation Z

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

Troutman Pepper Locke on

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

Ballard Spahr LLP

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

Ballard Spahr LLP on

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

Stinson LLP

New CFPB Interpretive Rule to Regulate BNPL

Stinson LLP on

The Consumer Financial Protection Bureau (CFPB ) has issued an interpretive rule stating that Buy Now, Pay Later (BNPL) loan providers are "card issuers" under Subpart B of Regulation Z and are thus subject to certain...more

Troutman Pepper Locke

South Carolina Proposes Legislation to Impose Ability-to-Repay Analysis for Installment and Payday Loans

Troutman Pepper Locke on

On January 9, a group of five bi-partisan South Carolina Senators introduced Bill 910, which would, among other things, require persons (non-bank lenders) providing “consumer installment loans” or “deferred presentment loans”...more

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