Buy Now, Pay Later (“BNPL”) in its present form is not subject to most consumer protection regulation. This essay first explores what appropriate BNPL consumer protections might look like. It next discusses the extent to which states are trying to fill the regulatory gap.
By Jeff Sovern[1]
I. Introduction
Buy Now, Pay Later (“BNPL”) might not exist if not for regulation. That’s because the typical BNPL transaction was created to fit within gaps in existing federal regulation.[2] Ac
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