AFSA’s BNPL Comment Letter
AFSA’s State Government Affairs team and the Card Coalition submitted a joint comment letter to the New York State Department of Financial Services urging revisions to its proposed Buy-Now-Pay-Later (BNPL) rule. The letter supports DFS’s consumer protection goals but warns that the proposal, as drafted, could sweep in traditional credit products, duplicate existing regulatory requirements, and create significant operational challenges for lenders.
AFSA and the Card Coalition recommend a more tailored framework that reflects how BNPL products operate in the market, preserves access to responsible credit, and provides affected entities with clear guidance and sufficient time to comply.
This letter, along with SGA’s other recent letters, can be found on the direct advocacy section of AFSA’s website.
September 17th, 2026
Get The News You Need
Sign up for our daily newsletter to receive all the most important industry news and updates every weekday morning.
Recent Posts
- A New Financial Services Agenda
- C3 Index Sees Tough Times
- AFSA Extra Credit Podcast | AI Moves From Pilot to Production in Asset Finance
- 🚨THIS THURSDAY | AFSA Webinar | How Specialty Finance Leaders Can Use Tax Technology to Make Executive-Level Decisions
- 🚨THIS THURSDAY | AFSA Webinar | The Customer Portal Decision: Build In-House or Implement a Purpose-Built Portal?