February 2022

Last month, the Consumer Financial Protection Bureau (CFPB) issued orders to five companies offering buy now, pay later (BNPL) products, asking them to provide information on several topics, including:

  • Business models,
  • BNPL performance metrics,
  • Disclosures and other consumer protections,
  • User demographics, and
  • Data harvesting and monetization.

For more information the CFPB’s inquiry, please see our

In Almada v. Krieger, No. 21-55275 (9th Cir. Jan. 24, 2022), the Ninth Circuit partially reversed a decision by the U.S. District Court for the Southern District of California, granting summary judgment in favor of a debt collector in a Fair Debt Collections Practices Act (FDCPA) case. In doing so, it held that