News & Analysis as of

Truth in Lending Act (TILA) Disclosure Requirements Buy Now Pay Later (BNPL)

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

Venable LLP

CFPB Issues FAQs: Expands Interpretive Rule for BNPL Products

Venable LLP on

On September 18, the CFPB issued a set of Frequently Asked Questions (FAQs) related to Buy Now, Pay Later (BNPL) products. These FAQs follow the CFPB's release of the 2024 BNPL Interpretive Rule (Interpretive Rule), which...more

Davis Wright Tremaine LLP

Where to Begin With the CFPB's "Buy Now, Pay Later" Interpretative Rule...

The Consumer Financial Protection Bureau's interpretative rule provides that traditional "Buy Now, Pay Later" (BNPL) products – closed-end loans that do not have a finance charge and are repaid in four installments – are...more

Jenner & Block

Client Alert: Buy Now, Pay Later: A Roadmap for Providers as Regulators Continue to Increase Scrutiny

Jenner & Block on

Point-of-sale financing arrangements payable in four or fewer interest-free installments, known as buy now, pay later (BNPL) arrangements, have soared since their initial breakthrough during the pandemic. Unlike conventional...more

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