News & Analysis as of

Proposed Rules Buy Now Pay Later (BNPL)

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

A&O Shearman

UK FCA consults on BNPL rules for 15 July 2026

A&O Shearman on

The UK Financial Conduct Authority (FCA) has published consultation paper CP25/23, alongside a press release and new webpage, setting out its proposed rules for regulating Deferred Payment Credit (DPC), commonly known as Buy...more

A&O Shearman

UK CBA Panel issues statement on FCA's consultation paper on regulating BNPL products

A&O Shearman on

The Cost Benefit Analysis (CBA) Panel has issued a statement in response to the UK Financial Conduct Authority's (FCA) consultation paper on proposed rules to regulate Deferred Payment Credit (DPC) products, commonly known as...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

The continuing journey towards buy now, pay later regulation

A&O Shearman on

One could be forgiven, amidst the noise and glamour of the Leeds Reforms and the Mansion House speech, for having missed the snappily titled Financial Services and Markets Act 2000 (Regulated Activities etc.) (Amendment)...more

Hogan Lovells

BNPL: Buy Now, Regulate in 2026 - FCA publishes proposals

Hogan Lovells on

Key takeaways The FCA has published details of the ‘proportionate’, ‘flexible’ and outcomes-focused conduct regime it is proposing for newly regulated BNPL agreements. These include a pragmatic approach to documentation and a...more

Hudson Cook, LLP

Consumer Financial Services Bites of the Month - May 2025 - "The CFPB in the End of May"

Hudson Cook, LLP on

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

A&O Shearman

UK Government advances BNPL Regulation

A&O Shearman on

HM Treasury (HMT) has published a response to its 2024 consultation on regulating Buy-Now, Pay-Later (BNPL) products and laid the draft secondary legislation (Financial Services and Markets Act 2000 (Regulated Activities etc)...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

A&O Shearman

Buy Now Pay Later - The Journey Continues (and the end is nearly in sight)

A&O Shearman on

In an exciting week for consumer credit lawyers, in addition to the consultation paper on the reform of the Consumer Credit Act 1974 (CCA), we also have HM Treasury’s response to the feedback it received from the 61...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

Hudson Cook, LLP

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

Hudson Cook, LLP on

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

Ballard Spahr LLP

Chopra Delivers Testimony to Congress on Semi-Annual Report

Ballard Spahr LLP on

On June 4, 2024, the CFPB issued its Semi-Annual Report to Congress covering the period beginning April 1, 2023 and ending September 30, 2023. On June 12, 2024, CFPB Director Chopra appeared before the Senate Banking...more

Hudson Cook, LLP

CFPB Bites of the Month - 2023 Annual Review - Payments

Hudson Cook, LLP on

In this article, we share a timeline of our monthly "bites" for 2023 applicable to payments, along with some additional related information....more

Kaufman & Canoles

CFPB Proposes New Rule on Overdraft Practices

Kaufman & Canoles on

On January 18, 2024, the CFPB proposed an extensive (211-page) rule on overdraft practices applicable to Financial Institutions (FIs) of $10 billion or more in assets (so called “very large FIs”). The proposed rule would not...more

Nutter McClennen & Fish LLP

Nutter Bank Report: December 2023

A recent OCC report identified key issues facing the federal banking system, including increasing credit risk due to higher interest rates, increasing risk in commercial real estate lending, prolonged inflation, declining...more

Husch Blackwell LLP

CFPB Signals New Proposed Rule on Nonbank Supervision in the Consumer Payments Market

Husch Blackwell LLP on

The Consumer Financial Protection Bureau (CFPB) recently released its Spring 2023 rulemaking agenda, signaling an expansion of its supervisory authority over the payments market. Of particular interest is the introduction of...more

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