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Illinois Enacts Comprehensive Buy-Now-Pay-Later Law: Implications for Licensing, Bank Partnerships, and Program Structure

What Happened?

On June 25, 2026, Illinois enacted Senate Bill 3561, which establishes the Buy-Now-Pay-Later Loan Consumer Protection Act. The measure creates a new state-level licensing and regulatory framework governing certain buy-now-pay-later (“BNPL”) products offered to Illinois consumers.

The Act applies to closed-end consumer credit products offered in connection with a specific purchase of goods or services where the credit is either (i) payable in four or fewer installments or (ii) has a term of 120 days or less. The definition expressly includes both interest-free “pay-in-four” products and BNPL products that carry interest or finance charges.

With this legislation, Illinois joins a growing number of states seeking to impose a tailored regulatory framework on BNPL products. The law is effective immediately, although it includes a transitional compliance period for existing market participants.

Overview of the Act

At a high level, the Act:

  • Requires licensure for persons engaged in the business of offering BNPL loans in the state
  • Establishes a regulatory regime administered by the Illinois Department of Financial and Professional Regulation
  • Imposes consumer protection, underwriting, reporting, and examination requirements
  • Applies broadly to a wide range of market participants involved in BNPL programs
  • Provides that violations constitute an unlawful practice under the Illinois Consumer Fraud and Deceptive Business Practices Act

The Act also provides that BNPL loans made in compliance with its requirements are not subject to certain existing Illinois lending statutes, including the Consumer Installment Loan Act and the Payday Loan Reform Act.

Scope of Coverage: Broad and Functional

A defining feature of the Illinois law is its expansive approach to coverage. The Act applies not only to entities that directly originate BNPL loans, but also to persons that:

  • Arrange or broker loans
  • Acquire or hold whole or partial interests in loans
  • Act as agents or service providers in connection with BNPL programs

In addition, the Act includes anti-evasion language intended to capture transactions that are “in substance” loans or structured to avoid application of the statute.

This framing reflects a broader trend in state legislation focusing on functional activity and economic substance, rather than formal labels or contractual roles.

Merchant and Passive Investor Carve-Outs

The Act includes several notable exceptions:

  • Merchant platform exception: A merchant or platform is not covered solely by offering BNPL options to consumers, provided it does not originate, underwrite, service, or hold an ownership interest in the underlying loans.
  • Passive investor exception: Persons holding a partial interest in a BNPL loan as a passive investor are excluded, so long as they do not control origination or servicing functions.

These carve-outs are consistent with approaches seen in other recent legislation, but their practical scope will depend on how regulators interpret concepts such as “control” and “participation” in the lending program.

Bank Partnership and “True Lender” Considerations

Although the Act exempts banks, credit unions, and certain other depository institutions, it does not automatically exempt nonbank participants in bank-partner BNPL programs.

Instead, the statute’s broad applicability provisions—combined with its anti-evasion framework—suggest that Illinois regulators may evaluate BNPL programs based on economic interest and operational control, rather than the nominal identity of the originating lender.

As a result, fintech companies and other nonbank program participants should consider how their roles—particularly in marketing, underwriting, funding arrangements, and servicing—may be viewed under the Act.

Underwriting and Consumer Protections

The Act introduces a set of consumer protection requirements that align BNPL products more closely with traditional consumer lending obligations.

Among other things, the law:

  • Requires disclosure of loan terms, costs, and repayment structure
  • Mandates processes for handling consumer disputes and refunds
  • Imposes an expectation that lenders assess a borrower’s ability to repay prior to extending credit

While the statute does not prescribe a specific underwriting formula, it signals a shift toward ability-to-repay–type standards in the BNPL context.

Transition Period and Implementation Timeline

The Act provides a transition pathway for existing BNPL providers.

Specifically, a person that was offering BNPL products in Illinois prior to January 1, 2028, and submits a license application by that date, may continue operating while the application is pending.

Key Takeaways

The Illinois BNPL Act raises several important considerations for market participants:

  1. Licensing analysis will be broader than traditional lender-focused regimes. Entities involved in program structure, marketing, servicing, or funding should assess whether they fall within scope.
  2. Form will not control over substance. The Act’s anti-evasion provisions suggest regulators will look beyond contractual labels to determine who is effectively acting as the lender.
  3. Bank partnership structures may be subject to scrutiny. Nonbank participants should evaluate their role in underwriting, economic exposure, and program governance.
  4. Merchant and investor carve-outs are helpful—but limited. These exclusions depend heavily on the absence of operational control or program-level influence.
  5. Compliance will extend beyond licensing. The Act introduces substantive obligations around disclosures, underwriting, dispute resolution, and regulatory oversight.

Looking Ahead

Illinois’s enactment of a comprehensive BNPL framework reflects an accelerating trend toward state-level regulation of point-of-sale financing products.

As additional states consider similar legislation, market participants should expect continued divergence in regulatory requirements—and a growing need to align program structures with evolving expectations around licensing, consumer protection, and risk management.

FHFA Director Directs Fannie and Freddie to Consider Crypto Assets to Qualify for Mortgages

What Happened?

On June 26, Federal Housing Finance Agency (“FHFA”) Director William Pulte told Fannie Mae and Freddie Mac (the “government sponsored entities”) to draft policies that would consider a borrower’s cryptocurrency holdings as reserves or assets when qualifying for a mortgage, without requiring borrowers to convert those holdings into U.S. dollars, and cryptocurrencies under consideration would be those stored on a U.S.-regulated exchange.

Why It’s Important

Currently, cryptocurrency that has not been converted to U.S. currency cannot be considered when evaluating a borrower’s qualifications for a mortgage backed by the government sponsored entities. The Trump administration has expressed interest in bolstering and further legitimizing cryptocurrency in the U.S. financial system. Incorporating crypto assets into the housing industry would inextricably link crypto, a less established financial tool, to one of the most stable asset classes in America.

What To Do Next?

Fannie Mae and Freddie Mac are directed to develop proposals “as soon as reasonably practical.” Parties with an interest in housing finance should stay up to date with Fannie Mae and Freddie Mac announcements to see when proposals are published.

Financial Services Advisory | The (Bay) State of the Model Money Transmission Modernization Act

Executive Summary
7 Minute Read

Massachusetts has joined the growing list of states that have at least partially adopted the Model Money Transmission Modernization Act. Our Financial Services Group examines the model act, how the Bay State has adopted it, and the implications for money transmitters.

  • The Massachusetts act applies to any entity that transfers money within the United States
  • The act only applies to consumer transactions, a major difference from the national model
  • Requirements of the act take effect January 1, 2026

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Massachusetts is the first state of 2025 to sign its version of the Model Money Transmission Modernization Act into law. The model act is a set of nationwide standards for the supervision and regulation of money transmitters created by state and industry experts and approved by the Conference of State Bank Supervisors (CSBS) in 2021. Since then, 25 states have enacted legislation to adopt, in whole or in part, a version of the model act.

Both the governor and state commissioner of banks emphasized the need to protect consumers and pointed to the widespread use of peer-to-peer payment applications as an important reason for adopting the new law. While regulation of businesses offering peer-to-peer payment services may have been a goal, the new law is far more comprehensive than the current framework, which addresses cross-border money transmissions and the sale of checks or money orders.

Scope of the New Massachusetts Act

Historically, Massachusetts has only required entities engaging in the business of selling, issuing, or registering checks or engaging in foreign money transmission activities, such as facilitating cross-border transactions, to obtain licenses. The new law repeals the prior law and replaces it with a statutory framework influenced by the model act. The new law applies to any entity that provides transfers of money between individuals or entities within the United States if it does not otherwise qualify for an exemption.

Specifically, the new law regulates the following activities as “money transmission”: (1) the sale or issuance of payment instruments to a person in Massachusetts; (2) the sale or issuance of stored value to a person in Massachusetts; or (3) the receipt of money for transmission from a person in Massachusetts.

In addition to expanding the scope, the new law incorporates key provisions from the model act, including express exemptions for operators of payment systems providing processing, clearing, or settlement services and for entities acting as agents of payees in accordance with statutory requirements.

Comparison to Model Act

While closely modeled on the model act, the new law does differ from the model act in a few notable ways.

Expressly for consumer purposes only

The definition of “money transmission” in the new law refers to the provision of such services to individuals and corporate entities. At the same time, the definition is expressly limited to “transactions engaged in by a person for personal, family or household purposes.” This addition limits the scope of the new law to consumer purposes. In contrast, the model act does not specify the purpose of the transactions, implying that it applies to both consumer and commercial transactions.

Silent on payroll processing services

The new law did not adopt the model act’s explicit inclusion of “payroll processing services” in its definition of money transmission. However, it did not expressly exempt payroll services, as is the case in other states, such as California.

The Division of Banks has posted select opinions interpreting the current law, including one as recently as November 2024, providing guidance on the licensing requirements for payroll and employee benefit services. The division concluded the services provided by the payroll service provider were not licensable under the state’s laws on cross-border money transmissions because none of the services involved the “transfer of money to foreign countries,” although certain other check services were licensable under the state’s laws on the sale of checks or money orders.

In reaching this conclusion, the deputy commissioner of banks and general counsel cautioned that “legislation has been filed that would overhaul the licensing and regulation of money transmission and would include domestic money transmission within the licensure requirement.”

Although Massachusetts may interpret payroll processing services as falling under the category of commercial services exempted by the limitations on money transmission set forth in the new law, recent guidance has focused on the presence of foreign transmission activity as the determining factor in resolving the question of whether licensure is required.

Does not adopt virtual currency provisions

The new law did not adopt the virtual currency provisions of the model act. Opinions posted on the division’s website clarify that entities involved in virtual currency transactions, such as exchanges or kiosks, may not require a foreign transmittal agency license if their activities do not involve transmitting funds to foreign countries.

The division often concluded that these entities’ activities did not involve transmitting funds to foreign countries, which was the primary driver for requiring such a license. The division’s conclusions are based on the specific facts presented in each case, and different facts may lead to different outcomes. As Massachusetts begins regulating domestic transactions, it remains unclear whether the new law will be interpreted to apply to virtual currency transactions.

Impact on Current Licensees

Licenses obtained under the current law will remain in effect, but renewals for the year 2026 and after will need to be filed in accordance with the new law.

Existing licensees will need to comply with the requirements in the new law, including maintaining a surety bond, permissible investments, and meeting the tangible net worth requirements.

Effective Date

New laws take effect in Massachusetts 90 days after the governor signs the law, unless the new law is an emergency law or pertains to certain matters excluded under the Massachusetts Constitution, making the effective date of the new law April 1, 2025. The new law states that the majority of its requirements will take effect January 1, 2026. Persons engaged in money transmission in Massachusetts that are required under the new law to obtain licensure must file an application for licensure by June 1, 2026 and may continue their activities while their application is pending until the application has been approved, withdrawn, or denied.

Model Act Adoption Landscape

Many states have adopted the model act either wholly or in part since the CSBS approved the model act in 2021. These states include:

  • Arizona
  • Arkansas
  • California
  • Connecticut
  • Georgia
  • Hawaii
  • Illinois
  • Indiana
  • Iowa
  • Kansas
  • Maine
  • Maryland
  • Massachusetts
  • Minnesota
  • Missouri
  • Nevada
  • New Hampshire
  • North Dakota
  • South Carolina
  • South Dakota
  • Tennessee
  • Texas
  • Vermont
  • West Virginia
  • Wisconsin

States’ Partial Adoptions of the Model Act

The model act regulates money transmission by establishing licensing, financial security, and reporting requirements and includes exemptions for certain entity types. While the goal of the model act was harmonization in the money transmission industry, states have not uniformly adopted the model act, with some choosing to adopt only certain provisions and others choosing to exempt activities the model act defines as licensable.

One exemption that has seen inconsistent adoption is that of payroll processing services, with some states expressly exempting payroll processors, other states choosing to be silent on whether payroll processing services constitute money transmission, and a third approach, such as that taken in Iowa, where the state adopted an “agent of the payor” exemption that applies to payroll processing.

Additionally, the model act provides an option for states to impose uniform licensing and disclosure requirements on virtual currency business activity. Only a few states, including Maine and Minnesota, have opted to include the model act’s virtual currency provisions. Other states are continuing to regulate virtual currency activity either through new licensing regimes or through regulatory interpretations of their money transmission laws.

Despite improved alignment between the states, companies engaging or seeking to engage in money transmission activities must continue managing compliance individually for each state.

2025 Adoptions of the Model Act

Massachusetts is the latest state to regulate domestic money transmission. Nearly half the states that have adopted at least part of the model act did so in 2024. We anticipate momentum in adoption of the model act will continue this year. Some states, including Alaska, Idaho, and Virginia, have pending legislation to address whether the state will also adopt a form of the model act later in the year.

We further note that while states are continuing to consider adopting the model act, Kansas, South Carolina, and Wisconsin each have new money transmission laws based on the model act that went into effect January 1, 2025.


Originally published January 22, 2025.

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CFPB Approves Financial Data Exchange to Set Standards for 1033

What Happened?

Last week the CFPB issued an Order recognizing the Financial Data Exchange, Inc. (“FDX”) as the first standard setting body (“SSO”) under the CFPB’s Personal Financial Data Rights Rule (the “Rule”).  The Rule requires financial institutions, credit card issuers, and other financial providers (“Subject Entities”) to make available consumers’ financial data and transfer it to third parties, at the consumer’s request, for no charge.   The final version of the Rule was released in October, and it is the subject of a lawsuit filed by the Bank Policy Institute and the Kentucky Bankers Association.

Why does it Matter?

Background:

FDX is a standard-setting organization with more than 200 member organizations in the United States and Canada, including depository and non-depository commercial entities; data providers and data recipients; and others.  FDX’s stated primary purpose is to develop, improve and maintain a common, interoperable standard for secure consumer and business access to financial records.

SSOs:

The Role of SSOs is to issue consensus standards to help entities comply with the Rule, including protocols for secure data sharing.  In June 2024, the CFPB finalized a rule outlining the qualifications to become a recognized industry standard setting body. The CFPB identified five key qualifications that standard setting bodies must demonstrate in order to be recognized by the CFPB, including openness, transparency, balanced decision-making, consensus, and due process and appeals.

The CFPB’s recognition of FDX as an SSO is subject to a number of conditions, including:

  • Ban on “pay-to-play” and other conflicts of interest:  FDX is to develop standards to promote open banking without regard to sponsorships or other financial incentives to give certain market participants an unfair advantage.  FDX must ensure that the organization and its staff do not have any side arrangements that would skew its financial incentives toward particular entities.
  • Mandatory reporting on market adoption:  FDX is required to report to the CFPB on market use of its consensus standards and/or maintain a publicly available resource where companies can disclose their use of standards as well as any certifications of adherence to standards, for the benefit of open banking participants, regulators, and the public.
  • Transparency and availability of standards: FDX must make available to the public any consensus standards that it adopts and maintains, subject to reasonable safeguards, and to ensure that non-members have the same access as members do. FDX must also make publicly available information about its standards development and issuance processes.

What’s Next?

Although FDX was recognized as the first SSO, the CFPB continues to evaluate other applications for SSO recognition.  As these organizations will have significant impact on the way Subject Entities comply with the Rule, those entities should monitor the issuance of consensus standards as they develop.

Financial Services Advisory: The UK Introduces a New Reimbursement and Compliance Monitoring Regime for Authorised Push Payment Scams

Our UK Financial Services Group examine the UK’s new mandatory reimbursement rules that will require payment service providers (PSPs) to reimburse victims of scam transactions.

  • The new rules will apply to all PSPs that participate in CHAPS and the Faster Payments Scheme and that operate ‘relevant accounts’
  • Consumers still have a responsibility to exercise caution before claiming a reimbursement, but PSPs will now have to be more vigilant when processing authorised push payments
  • Under the new requirements, PSPs could be required to reimburse consumers up to £85,000 per scam claim, consistent with the Financial Services Compensation Scheme reimbursement limit

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Payment service providers that participate in the Faster Payment Scheme in the UK and make payments on behalf of consumers from UK accounts will soon be subject to the Faster Payments Scheme Reimbursement Rules. The rules will require (subject to certain exceptions) payment services providers that send or receive funds on behalf of consumers to reimburse consumers when the payment was authorised by the consumer as a result of a scam.

The rules come into force on 7 October 2024, so payment service providers that participate in the Faster Payment Scheme must ensure that they are prepared. In addition to registering with the Faster Payments Operator, in-scope payment service providers must ensure that they have the relevant procedures and practices in place to monitor for scam transactions through the Faster Payments Scheme to avoid having to reimburse victims for scam transactions.

Authorised push payment (APP) scams happen when a person uses a fraudulent or dishonest course of conduct to manipulate, deceive, or persuade someone into sending money to an account outside their control.

With the aim of identifying and reducing the number of APP scams, the Financial Services and Markets Act 2023 (FSMA 2023) placed a statutory obligation on the UK Payment Systems Regulator (PSR) to introduce a Reimbursement Requirement for APP scam payments made over the Faster Payments Scheme (FPS) given that the PSR has oversight over payment systems in the UK (as opposed to payment services which are regulated by the Financial Conduct Authority).

The PSR decided to implement a policy that requires APP scam victims to be reimbursed by payment service providers (PSPs) because they provide services that enable the transfer of funds using the FPS. This is known as the FPS Reimbursement Requirement. The PSR decided to implement this policy by requiring the Faster Payments Operator to put the FPS Reimbursement Requirement into the Faster Payments Scheme rules. The resulting rules are known as the FPS Reimbursement Rules and will come into effect on 7 October 2024.

Application
The new FPS Reimbursement Requirement will apply to all PSPs that directly or indirectly participate in the Faster Payments Scheme and that operate ‘relevant accounts’, which are accounts that are held in the UK and can send or receive payments using the FPS, but they do not include accounts provided by credit unions, municipal banks, and national savings banks.
The FPS Reimbursement Requirements only apply to FPS APP scam payments, which are fraudulent or dishonest acts or courses of conduct to manipulate, deceive, or persuade a consumer into transferring funds from the consumer’s relevant account to a relevant account not controlled by the consumer, if:

  • The transfer is executed through the FPS.
  • The recipient is not who the consumer intended to pay.
  • The payment is not for the purpose the consumer intended.

A consumer who has made one or more FPS APP scam payments is defined as a ‘victim’. Note that for these purposes, consumer includes micro-enterprises and charities.

FPS Reimbursement Requirement
The FPS Reimbursement Requirement requires a ‘sending PSP’ (the PSP that operates the account from which the FPS APP scam payment was made) to reimburse the victim of an FPS APP scam payment, subject to certain exceptions.

Reimbursable FPS APP Scam
An FPS APP scam is only reimbursable if the sending PSP determines that:

  • The Consumer Standard of Caution Exception does not apply or the victim was a vulnerable consumer when the APP scam payment was authorised.
  • The victim is not party to the fraud.
  • The victim is not claiming fraudulently or dishonestly.
  • The victim is not claiming for an amount which is the subject of a private civil dispute.
  • The victim is not claiming for an amount which the victim paid for an unlawful purpose.

Exceptions to the Reimbursement Requirement
PSPs are not required to reimburse an FPS APP scam payment when the Consumer Standard of Caution applies. The Consumer Standard of Caution Exception applies when a sending PSP can demonstrate that a consumer who has made an FPS APP scam claim has, as a result of gross negligence, not complied with one or more of the following standards (the Consumer Standard of Caution):

  • The consumer should have regard to any intervention made by their sending PSP or a competent national authority (CNA).
  • The consumer should, upon learning or suspecting that they have fallen victim to an APP scam, report the FPS APP scam claim promptly to their sending PSP.
  • The consumer should respond to any reasonable and proportionate requests for information made by their sending PSP.
  • The consumer should, after making an FPS APP scam claim, consent to the sending PSP reporting to the police on the consumer’s behalf or request they directly report the details of an APP scam to a CNA.

Note that the Consumer Standard of Caution Exception does not apply if the victim was a vulnerable consumer when they made at least one of the FPS APP scam payments in the FPS APP scam claim and this had a material impact on their ability to protect themselves from the scam.

Guidance on what is a ‘vulnerable customer’ is set out in the Financial Conduct Authority ‘Guidance for firms on the fair treatment of vulnerable customers’, which states that all customers are at risk of becoming vulnerable and this risk is increased by characteristics of vulnerability related to four key drivers:

  • Health – health conditions or illnesses that affect the ability to carry out day-to-day tasks.
  • Life events – life events such as bereavement, job loss, or relationship breakdown.
  • Resilience – low ability to withstand financial or emotional shocks.
  • Capability – low knowledge of financial matters, low confidence in managing money (financial capability), or low capability in other relevant areas such as literacy or digital skills.

The guidance also provides specific examples.

In its consultation paper, the PSR describes ‘gross negligence’ as a ‘very high bar which will critically depend on the individual circumstances of each case’. It interprets gross negligence to be ‘a higher standard than the standard of negligence under common law’, with the consumer having to have shown a ‘very significant degree of carelessness’.

Time Limits to Claim Reimbursement
PSPs are not required to reimburse FPS APP scam payments reported more than 13 months after the date of the final FPS APP scam payment of the claim (consistent with the timeframes for reimbursement for unauthorised payments under the Payment Services Regulations 2017) or FPS APP scam payments that occurred before 7 October 2024.

Maximum Amount of Reimbursement
PSPs are not required to reimburse APP scam victims above the maximum level of reimbursement, even if the consumer was assessed as vulnerable. The PSR had previously set the maximum level at £415,000 in line with the Financial Ombudsman maximum reimbursement limit. However, after a brief consultation, the PSR recently decided to lower this amount to £85,000 per FPS APP scam claim, in line with the maximum level of reimbursement set under the Financial Services Compensation Scheme.

Assessment of FPS APP Scams
Once a sending PSP receives a reported FPS APP scam, the sending PSP must notify the receiving PSP (the PSP providing the relevant account into which APP scam payments are received) within two hours of the claim being reported. The receiving PSP then has the opportunity to respond to the sending PSP with any information it believes to be relevant to the FPS APP scam claim, up to a maximum of three business days after the notification from the sending PSP of the claim being raised.

The sending PSP cannot complete its assessment of the FPS APP scam claim until either the opportunity to respond has elapsed or all receiving PSPs have responded to the notification.

Payment of the Reimbursable Amount
If the sending PSP determines that the reported FPS APP scam payments are reimbursable, it must pay the reimbursable amount to the victim of the scam within five business days of the claim being raised.
Sending PSPs may pause the five-business-day reimbursement timescale by using the ‘stop the clock provision’ only when it has requested further information to assess the reported FPS APP scam claim. However, in any case, the sending PSP must complete the assessment, decide whether the FPS APP scam claim is to be reimbursed or not, and close the claim before the end of the thirty-fifth business day following the reporting of the FPS APP scam claim.

Excess
The sending PSP may apply a single claim excess to each FPS APP scam claim, up to the maximum claim excess value set by the PSR (£100). However, sending PSPs may not apply an excess if the victim was a vulnerable consumer.

Payment of the Reimbursable Contribution Amount
Once a sending PSP has paid the reimbursable amount to the victim of the FPS APP scam, then the reimbursable contribution amount shall become payable by the receiving PSP. The result is that both sending PSPs and receiving PSPs must be vigilant when processing payments through the Faster Payments Scheme.

The reimbursable contribution amount owed by the receiving PSP to the sending PSP is half the reimbursable amount and would be proportioned if there is more than one receiving PSP. The reimbursable contribution amount is payable within five business days following notice from the sending PSP.

Key Milestones
The FPS Reimbursement Rules set out certain key milestones:

  • By 20 August 2024, all in-scope PSPs must have registered with the Faster Payments Operator for the purposes of identification within the FPS reimbursement directory, reporting data, and compliance monitoring and management.
  • By 20 September 2024, all in-scope PSPs must have been onboarded to the Reimbursement Claims Management System (RCMS) Core for the purposes of accessing the FPS reimbursement directory, reporting data, and compliance monitoring and management.
  • From the proposed date of 1 May 2025, all in-scope PSPs must be onboarded to the RCMS Core + Claims and using the system to complete all actions required of them as defined by the FPS Reimbursement Rules to manage FPS APP scam claims, communicate with PSPs about FPS APP scam claims, and comply with the information collation, retention, and provision obligations.

Extension to CHAPS Payments
The Bank of England, as the operator of CHAPS, also published its draft of the CHAPS Reimbursement Rules in May 2024 and updated them in August 2024.

The intention of the new requirements is to mirror the protections set to be afforded to victims of APP scams who lose money via the FPS and to provide consistent outcomes, as well as consistent processes for firms, across both payment systems.

The PSR also published a policy statement and Specific Direction 21 on 6 September 2024. The Specific Direction requires banks and other PSPs participating in CHAPS to comply with the Bank of England’s new CHAPS Reimbursement Rules. It also confirmed that the CHAPS Reimbursement Rules will also come into force on 7 October 2024 in line with the FPS Reimbursement Requirements.


Originally published October 2, 2024.

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If you have any questions, or would like additional information, please contact one of the attorneys on our Financial Services Team.