Court Rules
All enforcement actions
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"

Related Enforcement Actions

CT

National Highway Traffic Safety Administration

Connecticut Attorney General William Tong joined a coalition of states and local governments in filing suit against NHTSA over its rule weakening fuel economy standards for new passenger cars and light trucks. The lawsuit alleges the rule violates the agency’s statutory mandate and the Administrative Procedure Act; no penalty or final remedy is reported.

CT

U.S. Environmental Protection Agency

Connecticut Attorney General William Tong joined a multistate coalition suing the EPA over its repeal of greenhouse gas pollution limits for power plants and separately filed a notice of intent to sue over regulation of existing gas plants. The coalition asks the court to overturn the repeal and restore the protections; the release reports no monetary penalty or final order.

CT

Sandoz Inc. and Fougera Pharmaceuticals Inc.

$400.0M

Connecticut Attorney General William Tong announced a $400 million settlement with Sandoz Inc. and Fougera Pharmaceuticals Inc. resolving allegations that the generic drug manufacturers conspired to inflate prices, limit competition, and restrain trade. The settlement includes consumer restitution and injunctive reforms; court approval was being sought.

CT

U.S. Department of Homeland Security

Connecticut Attorney General William Tong joined a coalition of 21 attorneys general in submitting a comment letter opposing a DHS rule that allows certain affirmative asylum applications to be referred to removal proceedings without an asylum officer interview. The coalition argues the rule violates federal law and harms asylum seekers, including unaccompanied children; this was a policy opposition letter, not a privacy enforcement action.

CT

NextEra Energy and Dominion Energy

Connecticut and Massachusetts co-led a coalition protest urging FERC to reject the proposed NextEra Energy-Dominion Energy merger. The coalition argued that the merger could increase market power and threaten energy affordability, reliability, and competition; the release does not report a final enforcement decision or penalty.

CT

Unspecified home improvement contractors

Connecticut officials warned residents about potential home improvement scams before an approaching nor’easter, including unlicensed contractors, high-pressure sales tactics, and demands for full payment upfront. The release provides consumer guidance on checking contractors and contract requirements; it does not announce an enforcement action or penalty against a named entity.