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ARTICLE · 18 MARCH 2026

NYDFS Teases Extensive New BNPL Requirements In Pre-Proposal Rulemaking Activity

Mayer Brown
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New York's pioneering Buy-Now/Pay-Later ("BNPL") Law is one step closer to taking effect with the issuance of pre-proposed regulations by the state's Department of Financial Services...

United StatesFinance and Banking
Eric T. Mitzenmacher
Eric T. Mitzenmacher
Daniel Pearson
Daniel Pearson
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New York's pioneering Buy-Now/Pay-Later ("BNPL") Law is one step closer to taking effect with the issuance of pre-proposed regulations by the state's Department of Financial Services ("NYDFS") on February 23, 2026.

Mayer Brown previously reported on the May 2025 enactment of the New York Buy-Now-Pay-Later Act (the "NY BNPL Act"), the first state law to regulate BNPL transactions comprehensively as a financial product distinct from other forms of lending. Rather than being self-effecting, the NY BNPL Act required the NYDFS to engage in rulemaking to implement the statute's licensing, loan term, disclosure, and practice provisions. The pre-proposed regulations are an incremental step towards effectiveness of the NY BNPL Act, though the NYDFS will still have to issue a formal proposal, take further public comments on such proposal for a period of at least 60 days following publication of the formal proposal, and only then adopt final rules that would take effect 180

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