On April 8, Michael Aphibal, Andrew Bigart, and Jonathan Pompan published “NYDFS Proposes Comprehensive Rules for Buy Now, Pay Later Lenders” in insideARM. The following is an excerpt:
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 Law) in 2025, and the New York Department of Financial Services (NYDFS) has now published a proposed rule implementing that Act. The proposal is currently in a pre-proposal outreach phase.
NYDFS’s proposal is notable not only because it would require most BNPL lenders to obtain a New York license, but also because it would impose a detailed conduct regime resembling a hybrid of closed-end Truth-in-Lending disclosures, credit-card-style billing error and unauthorized-use protections, and significant limits on fees, payment practices, and data use. In other words, it is a full consumer-credit playbook, not a light-touch fintech registration.
Click here to access the article.