United States: Buy Now, Regulate Later No More

In brief

New York’s Department of Financial Services has proposed rules that would fundamentally reshape the regulatory treatment of Buy Now, Pay Later products in the state. By extending consumer credit licensing and supervisory requirements to BNPL – including interest free, pay in four structures – the proposal moves BNPL into a fully supervised framework. The rules would impose new obligations across the BNPL lifecycle, from product design and underwriting through disclosures, servicing, data use, and ongoing compliance, with meaningful implications for New York market participation.

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