Part of the consumer dispute playbook.
CFPB Will Not Prioritize Enforcement of Its 2024 Buy Now, Pay Later Rule
The Consumer Financial Protection Bureau announced on May 6, 2025, that it will not make enforcement of its 2024 Buy Now, Pay Later rule a priority. That rule had extended Truth in Lending Act protections to BNPL digital account products.
What this means for you
When a federal agency steps back from enforcing a rule, the protections that rule was designed to provide may be less likely to be applied in practice — even if the rule itself remains on the books. Consumers who use BNPL products to make purchases should be aware that the disclosure and dispute-resolution standards the 2024 rule would have required may not be consistently enforced right now. Keeping your own records of BNPL purchase terms, payment schedules, and any communications with the lender can be especially useful in this kind of regulatory gap.
The facts
- The CFPB announced it will not prioritize enforcement actions based on its Buy Now, Pay Later rule published at 89 Fed. Reg. 47,068 on May 31, 2024.per the CFPB Newsroom · as of May 6, 2025
- The 2024 rule in question applied Truth in Lending Act (Regulation Z) requirements to digital user accounts used to access Buy Now, Pay Later loans.per the CFPB Newsroom · as of May 6, 2025
- The original Buy Now, Pay Later rule was published in the Federal Register on May 31, 2024.per the CFPB Newsroom · as of May 6, 2025
- This announcement reflects a shift in agency enforcement priorities, not a formal repeal of the rule itself.per the CFPB Newsroom · as of May 6, 2025
What you can do
Saving screenshots or copies of the terms shown at checkout before you complete a BNPL purchase creates a personal record if questions arise later. Noting payment due dates and amounts in writing — separate from the app — helps you track obligations independently of the lender's platform. If a billing problem comes up, filing a complaint with the CFPB or your state attorney general's office is one way to put your concern on record.
Common questions
What did the CFPB announce about Buy Now, Pay Later enforcement in May 2025?
The CFPB announced it will not prioritize enforcement of its 2024 rule that applied Truth in Lending Act requirements to Buy Now, Pay Later digital account products. The rule, published May 31, 2024, remains on the books, but the agency has indicated it will not focus its enforcement resources on violations of that specific rule.
Does the CFPB's enforcement pullback mean BNPL lenders can do whatever they want?
Not exactly. A change in enforcement priorities means the agency is less likely to pursue cases based on that particular rule, but other federal and state consumer protection laws may still apply to BNPL products. Consumers who experience problems still have options, including filing complaints with the CFPB or state regulators.