News & Analysis as of

Buy Now Pay Later (BNPL)

Alston & Bird

Fintech Case Files | May 2026

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The latest edition of the Fintech Case Files, our roundup of key litigation and enforcement involving the payments and fintech industries, features the latest challenges and uncertainty around Illinois’s Interchange Fee...more

Troutman Pepper Locke

Senate Democrats Seek Information from Consumer Reporting Agencies on Buy Now, Pay Later Reporting

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On May 6, several Senate Democrats sent letters to three nationwide consumer reporting agencies (CRAs) requesting detailed information about how Buy Now, Pay Later (BNPL) loans are being handled in consumer reporting. The...more

Ballard Spahr LLP

CFPB’s OIG investigating current workforce and contracting developments plus interpretations adopted and enforcement actions taken...

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The CFPB’s Office of Inspector General is still investigating the agency’s workforce and contracting moves to see what impact it has had on agency actions. “We are reviewing the CFPB’s workforce and contracting actions to...more

Hogan Lovells

Consumer credit: UK FCA proposes simplifications to financial promotions rules

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The FCA has published a combined consultation and discussion paper (CP26/15) on simplifying its financial promotions rules for consumer credit. This stems from the FCA's Consumer Duty Rule Review work, as well as industry...more

Troutman Pepper Locke

Point-of-Sale Finance Series: Fair Lending Risks at the Checkout Counter — Payments Pros – The Payments Law Podcast

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In this special joint episode of Payments Pros and The Consumer Finance Podcast, guest host Taylor Gess joins Chris Willis and Lori Sommerfield to unpack fair lending risks in point-of-sale finance. They explain how...more

Mayer Brown

Navigating Complexity in US Consumer Financial Services: A Look Back at 2025

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Mayer Brown’s broad Financial Services practice has a long history of providing meaningful insights on how rapidly evolving environments for financial products may affect their business activities through both thought...more

A&O Shearman

UK FCA directions for the temporary permission regime for deferred payment credit in force

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The UK Financial Conduct Authority (FCA) has published an updated webpage with newly issued directions, setting out the process for firms to register for the temporary permission regime (TPR) for deferred payment credit...more

Ballard Spahr LLP

Consumer Finance Monitor Podcast Draws Coverage from “Inside the CFPB”: A First for Our Platform

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In its April 6, 2026 issue, “Inside the CFPB,” a widely read subscription publication published by “Inside Mortgage Finance Publications” highlighted our recent podcast episode released on April 2, 2026 featuring discussion...more

Blank Rome LLP

New York Just Changed the Game for Buy Now, Pay Later

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New York became the first state to publish comprehensive regulations governing Buy Now, Pay Later (“BNPL”) financing on February 23, 2026, and the implications for retail finance are significant. The proposed rule implements...more

A&O Shearman

UK FCA Annual Work Programme 2026/27

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The UK Financial Conduct Authority (FCA) has published its annual work programme for 2026/27 setting out its planned activity for the second year of its five-year strategy. ...more

Goodwin

Payday and Small-Dollar Lending - March 2026

Goodwin on

Welcome to the eighth chapter of our annual report, Consumer Financial Services: 2025 Year in Review. In 2025, the Consumer Financial Protection Bureau (CFPB) reduced its scrutiny of small-dollar lenders by publicly...more

Hudson Cook, LLP

Consumer Financial Services Bites of the Month - March 2026 - "March Wind's Gonna Blow My Blues All Away."

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In this month's article, we share some of our top "bites" covered during the March 2026 webinar....more

McDermott Will & Schulte

New York proceeds with expansive regulation of buy now, pay later products

On February 23, 2026, the New York State Department of Financial Services (NYDFS) published a proposed regulation (the Proposed Regulation) implementing the state’s Buy Now, Pay Later (BNPL) Act, which was signed into law by...more

Ballard Spahr LLP

CRS says policymakers are facing myriad of BNPL issues

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Although an interpretive rule that made Buy Now Pay Later (BNPL) services subject to the Truth in Lending Act has been withdrawn, the issue remains a flashpoint in the industry and among policymakers, according to the...more

Skadden, Arps, Slate, Meagher & Flom LLP

Consumer Financial Enforcement: States to Watch in 2026

The past year has seen unprecedented change at the federal level, including the dramatic scaling back of consumer financial services enforcement activity at the Consumer Financial Protection Bureau (CFPB)....more

Mayer Brown

NYDFS Teases Extensive New BNPL Requirements in Pre-Proposal Rulemaking Activity

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New York’s pioneering Buy-Now/Pay-Later (“BNPL”) Law is one step closer to taking effect with the issuance of pre-proposed regulations by the state’s Department of Financial Services (“NYDFS”) on February 23, 2026....more

Holland & Knight LLP

From Statute to Supervision: Preparing for New York's New BNPL Regulatory Regime

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Gov. Kathy Hochul and the New York Department of Financial Services (DFS) on February 23, 2026, issued a Draft Proposal that would, for the first time, establish a comprehensive regulatory framework for buy-now-pay-later...more

A&O Shearman

UK FCA Handbook Notice 138

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The UK Financial Conduct Authority (FCA) has published Handbook Notice 138, outlining amendments to the FCA Handbook resulting from the following statutory instruments:...more

Venable LLP

NYDFS Proposes Comprehensive Rules for Buy Now, Pay Later Lenders

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New York is moving to establish a dedicated licensing and consumer-protection regime for Buy Now, Pay Later (BNPL) products. The New York legislature enacted the Buy Now Pay Later Act (Article 14-B of the New York Banking...more

Goodwin

New York Proposes New Regulations for Buy-Now-Pay-Later Loans

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Welcome to Goodwin’s Financial Services News Roundup. Our newsletter highlights important legal, regulatory, and business developments related to financial services and banking....more

A&O Shearman

UK PSR Seeks Views On Draft Merchant Survey Questionnaire For Cross Border Interchange Fees

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The UK Payment Systems Regulator (PSR) has published an invitation to comment on a revised draft questionnaire for a proposed survey of UK merchants as part of its review of cross border interchange fee remedies. The survey...more

Cooley LLP

New York Leads the Way on Buy Now, Pay Later Regulation

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New York has taken a significant step toward comprehensive regulation of buy now, pay later (BNPL) by requiring licensure and disclosures designed for credit cards, even though BNPL transactions are closed end....more

Orrick, Herrington & Sutcliffe LLP

New York Proposes Comprehensive BNPL Rule: What BNPL Providers Need to Know

On February 23, 2026, the New York State Department of Financial Services (DFS) proposed new regulations to implement the Buy-Now-Pay-Later Act enacted in May of last year. If adopted, the proposed rule would regulate the...more

Hogan Lovells

The Payments Newsletter including Digital Assets & Blockchain, February 2026

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Key developments of interest over the last month include: the UK government publishing a Payments Forward Plan setting out a regulatory roadmap for the payments sector over the next three years; the German Federal Ministries...more

BCLP

New York's Proposed Regulations for Buy Now, Pay Later Consumer Finance Services

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Buy-now, pay-later plans have seen rapid and widespread popularity among consumers and retailers. Acting in a perceived regulatory vacuum at the federal level, New York has adopted legislation to protect consumers as part of...more

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