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Financial Regulatory Reform Consumer Lenders Buy Now Pay Later (BNPL)

Troutman Pepper

Troutman Pepper Weekly Consumer Financial Services Newsletter - September 2024 #4

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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

Troutman Pepper

CFPB’s Latest FAQs Broaden Interpretive Rule for Pay-in-Four BNPL Products

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On September 18, the Consumer Financial Protection Bureau (CFPB or Bureau) issued a set of frequently asked questions (FAQs) providing guidance on applying Regulation Z requirements to Pay-in-Four Buy Now, Pay Later (BNPL)...more

Troutman Pepper

Troutman Pepper Weekly Consumer Financial Services Newsletter - August 2024 # 4

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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 Proposes Interpretive Rule that EWAs Are Credit; Expedited Funding Fees and Tips May Be Finance Charges under Regulation Z

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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

Troutman Pepper

CFPB's New Interpretive Rule: Buy Now, Pay Later as Credit Cards — The Consumer Finance Podcast and Payments Pros Podcast

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In this special crossover episode of The Consumer Finance Podcast and Payments Pros Podcast, Chris Willis and Josh McBeain interview two colleagues who delve into the Consumer Financial Protection Bureau’s (CFPB) recent...more

Wilson Sonsini Goodrich & Rosati

CFPB’s New Interpretive Rule Takes Aim at BNPL Payment Plans: Practical Takeaways

Providers of Buy Now, Pay Later (BNPL) payment plans are, for purposes of consumer financial protection laws, lenders subject to some of the same regulatory requirements as credit card issuers, under a recent interpretive...more

Skadden, Arps, Slate, Meagher & Flom LLP

CFPB Applies Credit Card Rules to 'Buy Now, Pay Later' Lenders

Following its recent win before the Supreme Court, the Consumer Financial Protection Bureau (CFPB or Bureau) on May 22, 2024, issued an interpretive rule concluding that “Buy Now, Pay Later” (BNPL) loans accessed through a...more

Stinson LLP

New CFPB Interpretive Rule to Regulate BNPL

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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

Troutman Pepper

Troutman Pepper Weekly Consumer Financial Services Newsletter - May 2024 # 4

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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 Issues “Interpretive Rule” Deeming BNPL Providers Card Issuers

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The result of the CFPB’s multi-year study of the BNPL industry is what the CFPB calls an interpretive rule in which it finds that: (1) “digital user accounts” (each a “DUA”) that may be used to access credit are “credit...more

Troutman Pepper

CFPB Rules Buy Now, Pay Later Lenders Must Offer Key Credit Card Protections

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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

Ballard Spahr LLP

CFPB Expected to Scrutinize Credit Card Rewards and Buy-Now-Pay Later Programs

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Consumer Financial Protection Bureau (“CFPB”) Director Rohit Chopra shared his insights at Consumer Bankers Association Live industry conference in Washington D.C. Reuters reported that Chopra told sideline reporters, “We are...more

Husch Blackwell LLP

A Closer Look at New York's Proposed Abusiveness Prohibition

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In January, New York Governor Kathy Hochul introduced a budget bill that proposed the headline-grabbing Buy Now Pay Later licensing regime. Less attention has been given to another proposed provision: adding a prohibition on...more

Ballard Spahr LLP

New York Governor’s Proposed TED Bill Includes Sweeping BNPL Legislation

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After promising earlier this year to “establish nation-leading regulations for the Buy Now Pay Later loan industry,” New York Governor Kathy Hochul took a significant first step in that direction by including Buy Now Pay...more

Troutman Pepper

NY Governor Announces Plans to Regulate “Buy Now, Pay Later” Industry

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On January 2, New York Governor Kathy Hochul unveiled her 2024 consumer protection agenda, which includes plans to regulate the “buy now, pay later” (BNPL) industry. Specifically, Governor Hochul plans to propose legislation...more

Ballard Spahr LLP

Democratic Senators urge continued CFPB scrutiny of buy-now-pay-later products

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Democratic Senator Sherrod Brown, who chairs the Senate Banking Committee, and Democratic committee members Raphael Warnock and John Fetterman, have sent a letter to Director Chopra urging the CFPB to “continue focusing on”...more

Davis Wright Tremaine LLP

Banking and Consumer Regulatory Digest - December 2023

Editor's Note - The following newsletter provides a roundup summarizing enforcement actions, guidance, rulemakings, and other public statements taken by a federal and/or state financial services regulatory agency,...more

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