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InvestigationMedium RiskMultistate

CT AG Tong Probes BNPL Firms on Fee Disclosures and Consumer Risk

Affirm, Afterpay, Klarna, PayPal, Sezzle, ZipDecember 1, 2025Connecticut Attorney General

Summary

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.

Contract Impact

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.

Contract Search Terms

BNPL termsinstallment paymentslate feesdisclosure requirementsconsumer protectionTruth in Lending Actcredit assessmentpayment schedulesfee transparencydebt traps

Laws Cited

Truth In Lending Act

Violation Types

Entity Details

Entity

Affirm, Afterpay, Klarna, PayPal, Sezzle, Zip

Also known as: Affirm

Industry

Financial Services

Multistate Coalition

Official Sources

Source Evidence

Entity Name
"Letters were sent to Affirm, Afterpay, Klarna, PayPal, Sezzle, and Zip."
Laws Cited
"the federal Truth In Lending Act (TILA)"
Violation Types
"BNPL products may expose consumers to unclear terms, hidden fees, and debt traps"

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