News & Analysis as of

Regulatory Requirements Buy Now Pay Later (BNPL)

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

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

Troutman Pepper Locke

Troutman Pepper Locke Weekly Consumer Financial Services Newsletter – July 2025 # 2

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

Husch Blackwell LLP

Five Things to Know About the New York Buy-Now-Pay-Later Act

Husch Blackwell LLP on

As part of an omnibus 2026 budget bill, New York passed a new law that will broadly govern point-of-sale (POS) installment financing offered to New York residents. The Buy-Now-Pay-Later (BNPL) Act was signed into law in early...more

Mayer Brown

Licensing Link - June 2025

Mayer Brown on

Licensing Link is a periodic publication that will keep you informed on hot topics and new developments in state licensing laws, and provide practice tips and primers on important issues related to state licensing across the...more

Mayer Brown

New York Enacts First-of-Its-Kind Law to License Buy-Now-Pay-Later Lenders

Mayer Brown on

The regulatory environment for “Buy Now, Pay Later” (or “BNPL”) loans is entering a new era. On May 9, 2025, New York enacted legislation that will require providers of BNPL loans to be licensed by the state and adhere to...more

Ballard Spahr LLP

New York Gov. Hochul signs legislation that includes BNPL Licensing Requirements and other Consumer Protection Provisions

Ballard Spahr LLP on

New York Gov. Kathy Hochul has signed legislation that, among other things, imposes new licensing requirements on Buy Now, Pay Later services....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

Sheppard Mullin Richter & Hampton LLP

CFPB Withdraws Dozens of Guidance Documents as Part of Deregulatory Push

On May 12, the CFPB formally withdrew nearly 70 guidance materials—including policy statements, advisory opinions, circulars, and interpretive rules—through a Federal Register notice issued by Acting Director Russell...more

Troutman Pepper Locke

Troutman Pepper Locke Weekly Consumer Financial Services Newsletter – May 2025 # 2

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

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

A&O Shearman

UK 2025 Regulatory Initiatives Grid published

A&O Shearman on

The Financial Services Regulatory Initiatives Forum (the Forum) has published the Regulatory Initiatives Forum Grid (the Grid), with the UK Financial Conduct Authority (FCA) also updating its webpage. The previous Grid was...more

A&O Shearman

UK FOS Plans and Budget published for 2025/2026

A&O Shearman on

The UK Financial Ombudsman Service (FOS) has published its plans and budget for 2025/2026, together with an accompanying press release. The FOS notes that there has been more uncertainty than usual over the last year, and...more

Kilpatrick

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

Kilpatrick on

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

Ballard Spahr LLP on

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

A&O Shearman

Buy-now, pay-later: what the future will (and might) hold for the sector

A&O Shearman on

KEY POINTS - - On the face of it buy-now, pay-later (BNPL), as an interest and charge free credit facility, appears low risk but couple its ready availability with the fact that it comes without any of the protections...more

Goodwin

2024 Year in Review: Payday and Small-Dollar Lending

Goodwin on

Welcome to the “Payday and Small-Dollar Lending” chapter of our annual report, Consumer Financial Services: 2024 Year in Review. We expect the level of enforcement and regulatory activity in the payday and short-term...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

K&L Gates LLP

Australia: ASIC Prepares Guidance Following the Release of BNPL Regulations

K&L Gates LLP on

On 5 February 2025, the Australian Government (via the Department of Treasury) released an exposure draft on the National Consumer Credit Protection Amendment (Low Cost Credit) Regulations 2025 (draft Regulations). The draft...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

A&O Shearman

HM Treasury Consults on Regulating Buy Now Pay Later

A&O Shearman on

HM Treasury has begun consulting on draft legislation regulating Buy Now Pay Later. HM Treasury is proposing to bring forward secondary legislation that would bring BNPL into Financial Conduct Authority regulation as soon as...more

Jenner & Block

Client Alert: Buy Now, Pay Later: A Roadmap for Providers as Regulators Continue to Increase Scrutiny

Jenner & Block on

Point-of-sale financing arrangements payable in four or fewer interest-free installments, known as buy now, pay later (BNPL) arrangements, have soared since their initial breakthrough during the pandemic. Unlike conventional...more

American Conference Institute (ACI)

[Event] 8th Forum on FinTech & Emerging Payment Systems - April 9th - 10th, New York, NY

ACI’s 8th Annual Legal, Regulatory, and Compliance Forum on Fintech & Emerging Payment Systems will provide in-depth guidance on the latest regulatory developments at the Federal and State Level that you need to be aware of....more

Sheppard Mullin Richter & Hampton LLP

CFPB Report Details Financial Profiles of BNPL Borrowers

On March 2, the CFPB published a report analyzing the financial profiles of consumers who borrow through buy now, pay later (BNPL) lending products. The report found that BNPL borrowers on average are more likely to be active...more

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