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Buy Now Pay Later (BNPL) Financial Services Industry Lenders

Sheppard Mullin Richter & Hampton LLP

CFPB Interpretive Rule Holds That BNPL Lenders Are Credit Card Providers

On May 22, the CFPB announced an interpretive rule confirming that Buy Now, Pay Later (BNPL) lenders qualify as credit card providers under the Truth in Lending Act, Regulation Z and are required to provide consumers legal...more

Orrick, Herrington & Sutcliffe LLP

New York State floats BNPL legislation in FY 2025 budget

On January 14, New York proposed its FY 2025 budget: Transportation, Economic Development and Environmental Conservation Article VII Bill, which includes an article, cited as the “Buy Now Pay Later Act” (the “Act”). The Act...more

Husch Blackwell LLP

The OCC Issues Bulletin Addressing Buy Now, Pay Later Lending

Husch Blackwell LLP on

What seems to have become a perennial topic for regulators, the Office of the Comptroller of the Currency (OCC) recently released OCC Bulletin 2023-37 to assist national banks and federal savings banks with effectively...more

Troutman Pepper

OCC Issues “Buy Now, Pay Later” Guidance to Banks

Troutman Pepper on

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

Ballard Spahr LLP

OCC issues guidance on managing risks associated with “buy now, pay later” lending

Ballard Spahr LLP on

The Office of the Comptroller of the Currency (OCC) has issued a bulletin (2023-37) that provides guidance on managing risks associated with “buy now, pay later” (BNPL) lending.  The BNPL loans addressed in the bulletin are...more

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