The Consumer Financial Protection Bureau (CFPB) has begun information-gathering inquiries into multiple companies that offer “buy now, pay later” (BNPL) credit to merchants and consumers, citing concerns about “accumulating debt, regulatory arbitrage, and data harvesting” affecting the consumer credit market.

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Photo of Benjamin M. Saul Benjamin M. Saul

Benjamin Saul is a shareholder in the firm’s Financial Regulatory and Compliance Practice. For two decades, Ben has handled high-stakes regulatory, enforcement, and litigation matters for corporate and individual clients in the consumer finance, specialty finance, fintech, and banking sectors.

Ben has helped

Benjamin Saul is a shareholder in the firm’s Financial Regulatory and Compliance Practice. For two decades, Ben has handled high-stakes regulatory, enforcement, and litigation matters for corporate and individual clients in the consumer finance, specialty finance, fintech, and banking sectors.

Ben has helped clients navigate dozens of contentious supervisory, enforcement, and litigation matters involving the Consumer Financial Protection Bureau (CFPB), and has been a leader in the private bar on CFPB matters since the Bureau’s inception in 2011. He also routinely assists clients in matters involving the FTC, DOJ, HUD, OCC, FRB, FDIC, state financial services authorities, state attorneys general, and state civil rights commissions. Ben’s enforcement matters have concerned fair lending and servicing, unfair deceptive and/or abusive trade practices, other federal and state consumer finance laws, AML/BSA, troubled or failed banks, fiduciary duties, financial institution fraud, supervisory ratings, and other safety and soundness issues.  These matters often have involved parallel proceedings by multiple enforcement agencies and/or private parties.

Ben also advises lenders, servicers, alternative financial service providers, and money service businesses on product and service development, licensing, compliance program enhancement, and the applicability of federal and state consumer credit and other financial services laws. He frequently helps clients understand how financial services law maps onto new technologies and innovative products, having worked on matters involving big data, artificial intelligence, marketplace and online lending, blockchain, digital assets and cryptocurrencies, digital banking, and payment systems.  In addition, Ben provides financial services regulatory support for corporate and capital markets transactions.

W. H. Langley Perry, Jr.

Langley Perry focuses his practice on federal and state regulatory compliance and state licensing for companies engaged in money transmission, consumer lending and loan servicing, commercial and residential mortgage services, debt collection, and other financial services.

Langley works on nationwide state money transmitter…

Langley Perry focuses his practice on federal and state regulatory compliance and state licensing for companies engaged in money transmission, consumer lending and loan servicing, commercial and residential mortgage services, debt collection, and other financial services.

Langley works on nationwide state money transmitter, lending, servicing, and other license acquisition projects. He provides compliance advice across a broad range of laws applicable to banks, money services businesses and non-bank consumer finance companies. He has experience handling Bank Secrecy Act/Anti-Money Laundering (BSA/AML) and Office of Foreign Assets Control (OFAC) compliance program reviews and development as well as matters involving the Financial Crimes Enforcement Network (FinCEN) and the Foreign Corrupt Practices Act (FCPA). He also advises clients on matters involving the Consumer Financial Protection Bureau (CFPB) and other federal and state regulatory authorities with oversight of consumer financial and payments products and services.