From Statute to Supervision: Preparing for New York's New BNPL Regulatory Regime

Gov. Kathy Hochul and the New York Department of Financial Services (DFS) on February 23, 2026, issued a Draft Proposal that would, for the first time, establish a comprehensive regulatory framework for buy-now-pay-later (BNPL) lenders operating in New York. The Draft Proposal would take effect 180 days after publication of the Notice of Adoption in the State Register.... By: Holland & Knight LLP