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
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