Overview
Partners Juliana Gerrick, Andrew Owens, Ben Saul, and associate Tarrian Ellis authored an article titled "Making Plans For BNPL Consumer Protection Compliance," which appeared in Law360.
The article looks at a new interpretive rule put in place by the Consumer Financial Protection Bureau that has the effect of requiring providers of closed-end buy-now, pay-later credit products to apply certain open-end credit consumer protections from the Truth in Lending Act and its implementing Regulation Z.