meta_id 3235853

On June 2026, the Oregon Division of Financial Regulation (DFR), part of the Department of Consumer and Business Services, issued Bulletin No. DFR 2026-X clarifying licensing requirements for non-bank lenders offering buy now, pay later (BNPL) products and BNPL service providers operating in Oregon. The bulletin establishes that non-bank BNPL lenders and service providers must obtain either a payday license or consumer finance license through the Nationwide Multistate Licensing System (NMLS) before transacting business in Oregon, regardless of whether the BNPL product is structured as non-recourse, carries no fees or interest at the point of sale, or involves late fees. The licensing requirement depends on the loan's repayment term. BNPL loans with repayment terms of 60 days or less fall under Oregon Revised Statutes (ORS) chapter 725A payday lending requirements. BNPL loans with periodic payments and terms longer than 60 days fall under ORS chapter 725 consumer finance licensing requirements. Both chapters apply to loans under $50,000. The DFR clarifies that BNPL loans do not qualify as "purchase money loans" and therefore are subject to licensing requirements. The bulletin defines key terms using Webster's Third International Dictionary and Oregon court precedent, establishing that BNPL loans constitute "loans" requiring repayment at a future date. Additionally, BNPL service providers functioning as brokers, facilitators, or agents must obtain appropriate licenses. The bulletin confirms that non-recourse loan structures do not exempt BNPL lenders from Oregon licensing requirements. The bulletin became effective upon publication in June 2026. Non-bank BNPL lenders and service providers can apply for Oregon payday and consumer finance licenses through the NMLS using links provided by the DFR.