Page 1 - gs251202_Flipbook

December 2025 • Issue 25:12:02

2025 year in review:

it was a happening year

Block's Afterpay, Klarna, PayPal, Sezzle and Zip – express-
ing concerns about protections that are being provided to
customers and underwriting practices.

Meanwhile BNPL is soaring. According to Adobe Analyt-
ics, consumers put $10.1 billion on BNPL plans between
Nov. 1 and Dec. 1, 2025, a 9 percent increase over the same
period in 2024.

But this growth has been accompanied by growth in late
payments. While defaults remain low (2 to 3 percent, ac-
cording to the Federal Reserve), 41 percent of BNPL users
made late payments this year, compared to 34 percent last
year, according to LendingTree. And BNPL loans are in-
terest free only if paid in full in the requisite time frame,
which can vary from six weeks to a year or more.
Big tech spared regulation

By Patti Murphy Congress quashed another CFPB rule giving the bureau su-
pervisory oversight of Big Tech companies' payment apps.
henever a new administration takes charge of The rule would have applied to companies handling at least
the federal government, businesses and indi- 50 million payments a year: Apple Pay, Google Pay, PayPal,
viduals alike brace for changes. Couple that Square and potentially X.
W with ongoing innovations in commerce and
payments – think artificial intelligence, digital payments, In January, X formed a partnership with Visa to power in-
crypto payments – and it's clear 2025 was a year brimming stant funding for its planned X Money peer-to-peer pay-
with change. ment account. The plan is to enable consumers to fund their
CFPB gets its wings clipped

One of the first things the Trump Administration did upon
assuming leadership was clip the wings of the Consumer Contributed articles inside by:
Financial Protection Bureau. First, it threw out an interpre-
tive ruling that subjected buy now, pay later companies to Allen Kopelman .....................................................................................18
the same consumer protection regulations that apply to
other lenders, like credit card companies. Chad Otar ................................................................................................20
Ken Musante ..........................................................................................26
BNPL providers' collective sigh of relief may be short lived,
however. State governments have signaled a desire to regu- Chris Jones ..............................................................................................28
late these companies. A multi-state coalition of attorneys Dale S. Laszig .........................................................................................30
general sent a letter to the six largest BNPL firms – Affirm,

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