The Buy Now, Pay Later Protection Act of 2025 (S.3561) introduces TILA compliance requirements for BNPL loans, directly increasing operating costs for Affirm ($AFRM) while benefiting established credit card issuers Capital One ($COF) and Synchrony ($SYF) who already comply. The bill is at early stage (referred to committee) with 4 cosponsors, making near-term passage uncertain but the regulatory direction is clear.
→ BNPL providers face increased compliance costs for loan origination and servicing, including system modifications, regulatory reporting, and potential liability for billing errors. Compliance cost estimates for similar TILA expansions range from $5M–$15M for medium-sized issuers.
S3561