Joint Trades Letter to New York State Department of Financial Services regarding proposed regulations implementing Article 14-B of the New York Banking Law governing BNPL lenders
We write to you as representatives of financial services companies and technology firms that offer products and services in New York to raise concerns with the New York State Department of Financial Services’ (NYDFS) proposed regulations implementing Article 14-B of the New York Banking Law governing buy now pay later (BNPL) lenders.
We support thoughtful regulation of innovative financial products and policies that protect consumers, reduce costs, and encourage choice. At the same time, we believe that this proposal may directly or indirectly capture entities that are not BNPL providers, potentially hurting the state’s business climate and the competitiveness of small and independent businesses that rely on this tool to support their customers. Separately, we are concerned that the proposal fails to calibrate its requirements to the comparatively low risk profile of BNPL products.