Yesterday, the Consumer Financial Protection Bureau (CFPB or Bureau) issued an “interpretive rule,” subjecting “Buy Now, Pay Later” (BNPL) transactions to provisions of Regulation Z applicable to “credit cards.” Among other...more
5/23/2024
/ Buy Now Pay Later (BNPL) ,
Consumer Financial Products ,
Consumer Financial Protection Act (CFPA) ,
Consumer Financial Protection Bureau (CFPB) ,
Consumer Lenders ,
Credit Cards ,
Debt Collection ,
Financial Regulatory Reform ,
Financial Services Industry ,
Interpretive Rule ,
Regulation Z ,
Truth in Lending Act (TILA)
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
1/29/2024
/ Ability-to-Repay ,
Borrowers ,
Buy Now Pay Later (BNPL) ,
Consumer Financial Products ,
Financial Regulatory Reform ,
Financial Services Industry ,
Loans ,
Non-Bank Lenders ,
Payday Loans ,
Proposed Legislation ,
Regulation Z
Late last month, Councilmember Kenyan R. McDuffie introduced B 25-0609, entitled the Protecting Affordable Loans Amendment Act of 2023, that proposes to opt the District of Columbia out of sections 521-523 of the Depository...more
12/29/2023
/ Banks ,
Consumer Financial Products ,
Consumer Lenders ,
DIDMCA ,
Financial Services Industry ,
FinTech ,
Loans ,
Opt-Outs ,
Proposed Regulation ,
Regulatory Agenda ,
True Lender ,
Usury
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
On October 9, a Florida state senator introduced SB 146, which would add a new section to the Florida Consumer Finance Act (CFA), attempting to curb evasion of the CFA. SB 146 would treat all payments incident to the loan as...more
On June 6, Nebraska Governor Jim Pillen signed into law Legislative Bill 92, which, among many other subjects, amends the Nebraska Installment Loan Act (the NILA). Previously, a license was required for a lender seeking to...more
As we reported here, late last year, the Consumer Financial Protection Bureau (CFPB) signaled that it planned to increase scrutiny of the Buy Now, Pay Later (BNPL) industry and issued its first report about BNPL. Yesterday,...more
On February 13, a bill was introduced in the Utah House of Representatives, entitled HB 455, that would add protections relating to credit obligations and certain installment contracts for service members assigned to a...more