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California Settlement Offers Reminder that Buy Now Pay Later Participants are Subject to California Financing Law

September 15, 2022 By Ross Speier and Josh Dhyani

In August 2022, the California Department of Financial Protection and Innovation (“Department” or “DFPI”) entered into a consent order with a company offering point of sale financing products that the DFPI deemed to be buy now, pay later (“BNPL”) financing, for which a California Financing Law (“CFL”) license is required. The company is required to […]

Filed Under: California, Consumer Loan, Licensing Tagged With: #BNPL, #California, fintech

Update Regarding the CFPB’s Buy Now, Pay Later Orders

January 7, 2022 By Consumer Finance Team

In a prior post, we reported that the language used in orders recently issued by the CFPB to leading Buy Now, Pay Later (“BNPL”) providers suggested that the CFPB intends to use the information it collects to build enforcement cases rather than monitor market developments. We also reported that if this is the case, it […]

Filed Under: Consumer Financial Protection Bureau (CFPB), Dodd-Frank Act, Fintech Tagged With: #BNPL, #CFPA, #CFPB

Is the CFPB using its market monitoring orders to build enforcement cases?

December 21, 2021 By Consumer Finance Team

As we previously noted, on October 21, the CFPB issued orders to six large technology firms seeking information about their payment product business plans (the “October 21 Orders”). According to the Bureau, the purpose of orders was to “shed light on the business practices of the largest technology companies in the world.” The CFPB’s use […]

Filed Under: Consumer Financial Protection Bureau (CFPB), Dodd-Frank Act Tagged With: #BigTech, #BNPL, #CFPB

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