Connecticut Attorney General William Tong led a multistate coalition in sending inquiry letters to six major BNPL providers—Affirm, Afterpay, Klarna, PayPal, Sezzle, and Zip—seeking detailed information on their pricing, fees, disclosures, and consumer assessment practices to evaluate compliance with consumer protection laws, following the rescission of federal Truth in Lending Act rules for BNPL.
In-house legal teams should review vendor agreements involving BNPL services to ensure compliance with consumer protection laws, including clear disclosure of all fees and terms, adherence to Truth in Lending Act credit disclosure requirements, and provisions for assessing consumers' ability to repay. Contracts should also address billing accuracy, dispute resolution processes, and transparency in payment schedules to mitigate risks of deceptive practices and debt traps.
Entity
Affirm, Afterpay, Klarna, PayPal, Sezzle, Zip
Also known as: Affirm
Industry
Financial ServicesOfficial Press Release
https://portal.ct.gov/ag/press-releases/2025-press-releases/attorney-general-tong-launches-inquiry-into-buy-now-pay-later-lenders
bnpl letters.pdf?rev=955e2e14ca3b485db8a692329b89d17b&hash=F
https://portal.ct.gov/-/media/ag/press_releases/2025/bnpl-letters.pdf?rev=955e2e14ca3b485db8a692329b89d17b&hash=F69EDF82FC2D63C7804FF4696BA43559
Connecticut Attorney General Enforcement Page
https://portal.ct.gov/AG/Privacy/Privacy-Resources
"Letters were sent to Affirm, Afterpay, Klarna, PayPal, Sezzle, and Zip."
"the federal Truth In Lending Act (TILA)"
"BNPL products may expose consumers to unclear terms, hidden fees, and debt traps"
$500K
Connecticut Attorney General William Tong announced settlements with SunRun, Inc., Elevate Solar Solutions, and two salespeople over allegations of deceptive solar sales, including impersonating consumers and locking homeowners into long-term contracts without consent. SunRun must pay $300,000 and provide consumer relief; Elevate and the salespeople face a stated $200,000 penalty, with $100,000 suspended subject to ongoing compliance.
$8.0M
Connecticut announced an $8 million settlement with Mylan over allegations that it used agreements to delay generic EpiPen competitors and took other actions that inflated prices. Mylan also agreed to provide 10,000 free EpiPens; the release states that Mylan denies wrongdoing.
Connecticut Attorney General William Tong joined a coalition of 22 attorneys general in filing an amicus brief challenging DHS’s policy and practice of conducting warrantless civil immigration arrests. The press release describes a court challenge, not a privacy enforcement action or monetary penalty.
$625K
Connecticut reached a $625,000 settlement with Frontier Communications Parent Inc. over an April 2024 breach in which compromised employee and vendor credentials were used to access internal systems and exfiltrate unencrypted personal information of 58,841 Connecticut residents. The settlement requires Frontier to strengthen its security program, implement specific safeguards and training, and obtain an independent third-party assessment.
$2.6M
Connecticut and New York found that Boston Children’s Health Physicians and its security vendor, XTIUM, failed to use reasonable safeguards, resulting in hackers accessing sensitive personal, medical, and employee information. The companies agreed to pay penalties totaling $2.64 million and implement enhanced cybersecurity measures.
Connecticut joined a coalition of state attorneys general filing a notice in Character Technologies, Inc.’s bankruptcy proceedings, raising concerns about the company’s safety and privacy practices and the sensitive information it holds. The states seek protections for children and consumers if the company’s business or assets are sold or transferred; the filing does not impose a fine or other remedy.