On August 3, 2022, the California Department of Financial Protection and Innovation (DFPI) announced that it had entered into a consent order with a Florida-based lending company that allegedly made "illegal loans." Specifically, the consent order alleges that the company's policy of making "buy now, pay later" arrangements for point-of-sale transactions qualified as "loans," subjecting the arrangements to DFPI's jurisdiction under California Financial Code § 22000 et seq. The DFPI further alleged that the company entered in to such transactions without obtaining a license from the DFPI.

The order assesses a $2,500 administrative penalty and requires the company to refund $13,065.68 that it charged in fees. In exchange, DFPI granted the company a California lending license.

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