News & Analysis as of

Truth in Lending Act (TILA) Loans Buy Now Pay Later (BNPL)

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

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

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

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