News & Analysis as of

Buy Now Pay Later (BNPL)

A&O Shearman

UK 2025 Regulatory Initiatives Grid published

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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

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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

Hogan Lovells

FCA Annual Work Programme 2025/26: A work plan reflecting the UK government’s pro-growth mission

Hogan Lovells on

Motor finance, mortgage rule review work and Consumer Duty feature prominently in the work plans for this strategic priority. Firms should note that the FCA includes a warning in relation to the Duty that, where necessary, it...more

Husch Blackwell LLP

The State of the CFPB During a Fraught Transition Period: Part II

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It has been a little over two months since President Donald Trump returned to office, and since then, the Consumer Financial Protection Bureau (CFPB) has been in flux—to put it mildly. As of this writing, it is unclear...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

Troutman Pepper Locke

Troutman Pepper Locke Weekly Consumer Financial Services Newsletter – April 2025

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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

CFPB plans to revoke BNPL interpretive rule

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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

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

A&O Shearman

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

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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

Venable LLP

Crossing the Pond: What UK Fintechs Taking a Fresh Look at the U.S. Market Need to Know

Venable LLP on

For years, UK-based consumer finance and payments firms have viewed the U.S. regulatory landscape as complex, fragmented, and challenging when it comes to expansion. But 2025 may prove to be a turning point....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

Hudson Cook, LLP

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

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

K&L Gates LLP

Australia: ASIC Prepares Guidance Following the Release of BNPL Regulations

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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

Hudson Cook, LLP

CFPB Bites of the Month - 2024 Annual Review - Fintech

Hudson Cook, LLP on

In this article, we share a timeline of our monthly "bites" for 2024 applicable to companies in FinTech. The Consumer Financial Protection Bureau was on a tear in the months leading up to the election and the inauguration of...more

Orrick, Herrington & Sutcliffe LLP

New York Governor Hochul proposes new financial protections

On January 14, Governor Kathy Hochul announced new proposals to protect New York consumers as part of her 2025 State of the State. Her proposals included legislation to: (i) combat algorithmic price discrimination by...more

Orrick, Herrington & Sutcliffe LLP

CFPB reports on consumer use of BNPL loan products, calls for further research into BNPL’s impact on consumers’ financial health

On January 13, the CFPB published a report analyzing consumers’ use of Buy Now, Pay Later (BNPL) loan products. This latest report builds on previous CFPB work related to BNPL lending by pairing a matched sample of BNPL...more

Troutman Pepper Locke

Troutman Pepper Locke Weekly Consumer Financial Services Newsletter – January 2025 # 3

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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

Sheppard Mullin Richter & Hampton LLP

CFPB Publishes Supervisory Highlights Focused on Deposits, Small-Dollar Lending, BNPL, and Paycheck Advance Products

During the week of January 6, the CFPB released a “second” Winter 2024 Supervisory Highlights, focused on the agency’s most recent findings in deposits, small dollar lending, buy now, pay later (BNPL), paycheck advance...more

Ballard Spahr LLP

Borrowers with poor credit ratings make up majority of BNPL borrowers

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Borrowers with subprime or deep subprime credit scores make up the majority of Buy Now, Pay Later (BNPL) originations, the CFPB said, in a new report. From 2021 to 2022, borrowers with deep subprime credit scores accounted...more

Troutman Pepper Locke

CFPB Releases Report Highlighting Consumer Use of Buy Now, Pay Later Products

Troutman Pepper Locke on

On January 13, the Consumer Financial Protection Bureau (CFPB or Bureau) released a report providing its analysis of the growth and impact of Buy Now, Pay Later (BNPL) loans in the United States since 2019. BNPL loans,...more

K&L Gates LLP

BNPL Regulation Takes the Final Step in Australia

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On 29 November 2024, the Australian Parliament passed the long-awaited Treasury Laws Amendment (Responsible Buy Now Pay Later and Other Measures) Bill 2024 (Bill)....more

Alston & Bird

Payments Docket – December 2024

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The latest edition of the Payments Docket, our roundup of key litigation and enforcement involving the payments industry, features why the CFPB’s open banking rule is under fire, a convenience fee that steals your lunch...more

Ankura

The CFPB Sets Its Sights on Buy Now, Pay Later Lenders in New Interpretive Rule

Ankura on

On May 22, 2024, the Consumer Financial Protection Bureau (CFPB) issued an interpretive rule identifying Buy Now, Pay Later Lenders (BNPL Lenders or Lenders) as “card issuers” or “creditors” for the purposes of Regulation Z,...more

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