Legal Counsel, Credit
for sections like About the role, Responsibilities, Requirements, Qualifications, Skills, Benefits, Pay, Schedule. Only include sections that have real specific content. We need to extract content from posting.
We have company description (maybe "About the role"? Actually "Job Summary" and "Job Description" etc). The page already shows job title, so we don't repeat it.
We need to include sections: maybe "About the role" (Job Summary), "Responsibilities" (Essential Responsibilities), "Requirements" (Minimum Qualifications), "Qualifications" (Additional Responsibilities & Preferred Qualifications) maybe combine? But we need to follow headings list: About the role, Responsibilities, Requirements, Qualifications, Skills, Benefits, Pay, Schedule.
We need to decide which sections have content.
- About the role: could be Job Summary (the paragraph after "Job Summary:").
- Responsibilities: Essential Responsibilities list.
- Requirements: Minimum Qualifications.
- Qualifications: Additional Responsibilities & Preferred Qualifications (maybe treat as Qualifications). Could also include Skills within that.
- Skills: maybe we can extract skills from Additional Responsibilities & Preferred Qualifications (like strong knowledge, exceptional legal research skills, etc). But we could also put them under Skills.
- Benefits: The "Our Benefits:" paragraph.
- Pay: The base pay ranges.
- Schedule: The hybrid work model description (3 days in office, 2 days remote). That's schedule info.
We must not include boilerplate like EEO, scam warnings, etc. Also remove duplicated lines.
We must preserve ALL substantive information; do not invent or summarize away detail. So we need to keep the details exactly as given, but we can format into HTML.
We need to use - for any list of duties/requirements/benefits, and
for prose.
We need to avoid headings with filler like "commensurate with experience". Not present.
We need to output only HTML fragment, no /, no markdown fences.
Let's extract content.
Company description: The first paragraph about PayPal. Is that part of "About the role"? Probably not; it's generic company overview. Might be considered "About the role"? The instruction: "Use
for section headings (e.g. About the role, Responsibilities, Requirements, Qualifications, Skills, Benefits, Pay, Schedule)." So we can include an "About the role" section that includes the job summary and maybe company overview? The job summary is specific to role. The company overview is generic but still substantive. We could include it under About the role.
But we must not repeat the job title as a heading. That's fine.
Let's parse:
Job Summary: "Join PayPal’s Legal team as counsel supporting PayPal-branded US consumer credit products. You will advise teams supporting merchants and partners on the end-to-end distribution and operation of credit products, including sales enablement and marketing. You will also provide legal and regulatory guidance on onboarding, servicing, issue and dispute resolution, and collections for open-end and closed-end consumer credit. This role offers the opportunity to navigate evolving financial services regulation, address matters of first impression, and help business partners deliver innovative credit experiences in a complex regulatory environment."
That's prose.
Essential Responsibilities: list bullet points (separated by periods? Actually they are sentences separated by periods but no bullet formatting. We need to turn into - . The list:
- Provide specialized legal advice and support to enable business strategy while identifying and managing legal risk.
- Ensure awareness of and advise on compliance with relevant laws and regulations.
- Build strong partnerships with business counterparts across the enterprise to proactively identify potential legal risks and provide strategic legal guidance.
- Identify, analyze, and advise on potential legal risks, presenting mitigation options and recommendations to protect the company and enable business objectives.
- Escalate complex legal issues and significant risks to senior legal leadership where appropriate.
- Research and analyze new laws, regulations, and regulatory guidance affecting the company's global operations, assessing potential business impact and recommended actions.
- Manage assigned legal matters through resolution, coordinating with internal stakeholders and external counsel as needed.
- Maintain current knowledge of legal developments relevant to assigned business areas and communicate implications.
We need to keep each as
- .
Minimum Qualifications: "5+ years relevant experience and a Juris doctorate degree OR Any equivalent combination of education and experience."
That's prose (maybe two options). Could be a
.
Additional Responsibilities & Preferred Qualifications: a list of items separated by periods. Let's extract each:
- Experience advising on legal and regulatory matters involving consumer credit and lending, financial services, consumer protection, sales, contracts, and marketing.
- Strong knowledge of laws and regulations applicable to consumer credit and payments, including UDAAP, EFTA/Reg. E, TILA/Reg. Z, GLBA/Reg. P, FCRA/Reg. V, FDCPA, ECOA/Reg. B, CAN-SPAM, and TCPA.
- Experience advising on e-commerce, payments, credit cards, or other consumer and small-business lending products.
- Experience supporting regulatory examinations and interactions with regulatory bodies, internal audits, and third-party audits.
- Exceptional legal research skills, including analyzing new legislation and regulation and applying evolving requirements to specific business use cases and matters of first impression.
- Ability to synthesize complex legal and regulatory requirements and provide clear, practical guidance to stakeholders across different levels of the organization.
- Admission to a U.S. state bar and in good standing.
- Exceptional legal drafting and writing skills, with strong attention to detail.
- Strong communication, collaboration, and problem-solving skills, with the ability to operate effectively in a fast-paced and evolving environment.
- Ability to take ownership of complex matters while collaborating effectively with legal colleagues and cross-functional partners across a global organization.
We could split into Qualifications and Skills sections. Perhaps Qualifications: the education/experience etc? But we already used Minimum Qualifications for that. Additional Responsibilities & Preferred Qualifications could be split into Qualifications and Skills. However we have headings: Qualifications, Skills. We need to decide what goes where.
We could put under Qualifications: items that are about experience/knowledge (like experience advising..., strong knowledge..., experience advising on e-commerce..., experience supporting regulatory examinations...). And under Skills: items like exceptional legal research skills, ability to synthesize..., admission to bar..., exceptional legal drafting..., strong communication..., ability to take ownership...
But the instruction: "Prefer a few substantive sections over many thin ones." So maybe we combine Qualifications and Skills into one section? But we have headings list; we can include both if they have content. It's okay to have multiple sections.
We need to avoid creating sections with filler. All these items are substantive.
Benefits: The paragraph under "Our Benefits:" includes multiple sentences. We'll put as
.
Pay: The base pay ranges: we have primary location and additional locations with pay ranges. Also mention additional compensation may include annual performance bonus, equity, or other incentive compensation. We'll include that as prose or list? Could be
.
Schedule: The hybrid work model: "For the majority of employees, PayPal's balanced hybrid work model offers 3 days in the office for effective in-person collaboration and 2 days at your choice of either the PayPal office or your home workspace, ensuring that you equally have the benefits and conveniences of both locations." That's schedule.
We must not include boilerplate like EEO, scam warnings, etc. Also remove duplicated lines.
Now construct HTML.
We'll start with
About the role
then include company overview and job summary? Might be too much but okay.
Better: About the role: include the company overview (first paragraph) and Job Summary. Could combine.
But we need to preserve all substantive information; we can include both.
Let's write:
About the role
The Company PayPal has been revolutionizing commerce globally for more than 25 years. Creating innovative experiences that make moving money, selling, and shopping simple, personalized, and secure, PayPal empowers consumers and businesses in approximately 200 markets to join and thrive in the global economy. We operate a global, two-sided network at scale that connects hundreds of millions of merchants and consumers. We help merchants and consumers connect, transact, and complete payments, whether they are online or in person. PayPal is more than a connection to third-party payment networks. We provide proprietary payment solutions accepted by merchants that enable the completion of payments on our platform on behalf of our customers. We offer our customers the flexibility to use their accounts to purchase and receive payments for goods and services, as well as the ability to transfer and withdraw funds. We enable consumers to exchange funds more safely with merchants using a variety of funding sources, which may include a bank account, a PayPal or Venmo account balance, PayPal and Venmo branded credit products, a credit card, a debit card, certain cryptocurrencies, or other stored value products such as gift cards, and eligible credit card rewards. Our PayPal, Venmo, and Xoom products also make it safer and simpler for friends and family to transfer funds to each other. We offer merchants an end-to-end payments solution that provides authorization and settlement capabilities, as well as instant access to funds and payouts. We also help merchants connect with their customers, process exchanges and returns, and manage risk. We enable consumers to engage in cross-border shopping and merchants to extend their global reach while reducing the complexity and friction involved in enabling cross-border trade. Our beliefs are the foundation for how we conduct business every day. We live each day guided by our core values of Inclusion, Innovation, Collaboration, and Wellness. Together, our values ensure that we work together as one global team with our customers at the center of everything we do – and they push us to ensure we take care of ourselves, each other, and our communities.
Job Summary: Join PayPal’s Legal team as counsel supporting PayPal-branded US consumer credit products. You will advise teams supporting merchants and partners on the end-to-end distribution and operation of credit products, including sales enablement and marketing. You will also provide legal and regulatory guidance on onboarding, servicing, issue and dispute resolution, and collections for open-end and closed-end consumer credit. This role offers the opportunity to navigate evolving financial services regulation, address matters of first impression, and help business partners deliver innovative credit experiences in a complex regulatory environment.
But note: The instruction: "Do NOT repeat the job title as a heading (the page already shows it) and do NOT put Job ID / requisition numbers as headings — fold minor metadata into a short or drop it." So we can keep Job Summary as a paragraph.
Now Responsibilities:
Responsibilities
- Provide specialized legal advice and support to enable business strategy while identifying and managing legal risk.
- Ensure awareness of and advise on compliance with relevant laws and regulations.
- Build strong partnerships with business counterparts across the enterprise to proactively identify potential legal risks and provide strategic legal guidance.
- Identify, analyze, and advise on potential legal risks, presenting mitigation options and recommendations to protect the company and enable business objectives.
- Escalate complex legal issues and significant risks to senior legal leadership where appropriate.
- Research and analyze new laws, regulations, and regulatory guidance affecting the company's global operations, assessing potential business impact and recommended actions.
- Manage assigned legal matters through resolution, coordinating with internal stakeholders and external counsel as needed.
- Maintain current knowledge of legal developments relevant to assigned business areas and communicate implications.
Requirements:
Requirements
Minimum Qualifications: 5+ years relevant experience and a Juris doctorate degree OR Any equivalent combination of education and experience.
Qualifications:
Qualifications
- Experience advising on legal and regulatory matters involving consumer credit and lending, financial services, consumer protection, sales, contracts, and marketing.
- Strong knowledge of laws and regulations applicable to consumer credit and payments, including UDA
for prose. We need to avoid headings with filler like "commensurate with experience". Not present. We need to output only HTML fragment, no /, no markdown fences. Let's extract content. Company description: The first paragraph about PayPal. Is that part of "About the role"? Probably not; it's generic company overview. Might be considered "About the role"? The instruction: "Use
for section headings (e.g. About the role, Responsibilities, Requirements, Qualifications, Skills, Benefits, Pay, Schedule)." So we can include an "About the role" section that includes the job summary and maybe company overview? The job summary is specific to role. The company overview is generic but still substantive. We could include it under About the role.
But we must not repeat the job title as a heading. That's fine.
Let's parse:
Job Summary: "Join PayPal’s Legal team as counsel supporting PayPal-branded US consumer credit products. You will advise teams supporting merchants and partners on the end-to-end distribution and operation of credit products, including sales enablement and marketing. You will also provide legal and regulatory guidance on onboarding, servicing, issue and dispute resolution, and collections for open-end and closed-end consumer credit. This role offers the opportunity to navigate evolving financial services regulation, address matters of first impression, and help business partners deliver innovative credit experiences in a complex regulatory environment."
That's prose.
Essential Responsibilities: list bullet points (separated by periods? Actually they are sentences separated by periods but no bullet formatting. We need to turn into - . The list:
- Provide specialized legal advice and support to enable business strategy while identifying and managing legal risk.
- Ensure awareness of and advise on compliance with relevant laws and regulations.
- Build strong partnerships with business counterparts across the enterprise to proactively identify potential legal risks and provide strategic legal guidance.
- Identify, analyze, and advise on potential legal risks, presenting mitigation options and recommendations to protect the company and enable business objectives.
- Escalate complex legal issues and significant risks to senior legal leadership where appropriate.
- Research and analyze new laws, regulations, and regulatory guidance affecting the company's global operations, assessing potential business impact and recommended actions.
- Manage assigned legal matters through resolution, coordinating with internal stakeholders and external counsel as needed.
- Maintain current knowledge of legal developments relevant to assigned business areas and communicate implications.
We need to keep each as
- .
Minimum Qualifications: "5+ years relevant experience and a Juris doctorate degree OR Any equivalent combination of education and experience."
That's prose (maybe two options). Could be a
.
Additional Responsibilities & Preferred Qualifications: a list of items separated by periods. Let's extract each:
- Experience advising on legal and regulatory matters involving consumer credit and lending, financial services, consumer protection, sales, contracts, and marketing.
- Strong knowledge of laws and regulations applicable to consumer credit and payments, including UDAAP, EFTA/Reg. E, TILA/Reg. Z, GLBA/Reg. P, FCRA/Reg. V, FDCPA, ECOA/Reg. B, CAN-SPAM, and TCPA.
- Experience advising on e-commerce, payments, credit cards, or other consumer and small-business lending products.
- Experience supporting regulatory examinations and interactions with regulatory bodies, internal audits, and third-party audits.
- Exceptional legal research skills, including analyzing new legislation and regulation and applying evolving requirements to specific business use cases and matters of first impression.
- Ability to synthesize complex legal and regulatory requirements and provide clear, practical guidance to stakeholders across different levels of the organization.
- Admission to a U.S. state bar and in good standing.
- Exceptional legal drafting and writing skills, with strong attention to detail.
- Strong communication, collaboration, and problem-solving skills, with the ability to operate effectively in a fast-paced and evolving environment.
- Ability to take ownership of complex matters while collaborating effectively with legal colleagues and cross-functional partners across a global organization.
We could split into Qualifications and Skills sections. Perhaps Qualifications: the education/experience etc? But we already used Minimum Qualifications for that. Additional Responsibilities & Preferred Qualifications could be split into Qualifications and Skills. However we have headings: Qualifications, Skills. We need to decide what goes where.
We could put under Qualifications: items that are about experience/knowledge (like experience advising..., strong knowledge..., experience advising on e-commerce..., experience supporting regulatory examinations...). And under Skills: items like exceptional legal research skills, ability to synthesize..., admission to bar..., exceptional legal drafting..., strong communication..., ability to take ownership...
But the instruction: "Prefer a few substantive sections over many thin ones." So maybe we combine Qualifications and Skills into one section? But we have headings list; we can include both if they have content. It's okay to have multiple sections.
We need to avoid creating sections with filler. All these items are substantive.
Benefits: The paragraph under "Our Benefits:" includes multiple sentences. We'll put as
.
Pay: The base pay ranges: we have primary location and additional locations with pay ranges. Also mention additional compensation may include annual performance bonus, equity, or other incentive compensation. We'll include that as prose or list? Could be
.
Schedule: The hybrid work model: "For the majority of employees, PayPal's balanced hybrid work model offers 3 days in the office for effective in-person collaboration and 2 days at your choice of either the PayPal office or your home workspace, ensuring that you equally have the benefits and conveniences of both locations." That's schedule.
We must not include boilerplate like EEO, scam warnings, etc. Also remove duplicated lines.
Now construct HTML.
We'll start with
About the role
then include company overview and job summary? Might be too much but okay.
Better: About the role: include the company overview (first paragraph) and Job Summary. Could combine.
But we need to preserve all substantive information; we can include both.
Let's write:
About the role
The Company PayPal has been revolutionizing commerce globally for more than 25 years. Creating innovative experiences that make moving money, selling, and shopping simple, personalized, and secure, PayPal empowers consumers and businesses in approximately 200 markets to join and thrive in the global economy. We operate a global, two-sided network at scale that connects hundreds of millions of merchants and consumers. We help merchants and consumers connect, transact, and complete payments, whether they are online or in person. PayPal is more than a connection to third-party payment networks. We provide proprietary payment solutions accepted by merchants that enable the completion of payments on our platform on behalf of our customers. We offer our customers the flexibility to use their accounts to purchase and receive payments for goods and services, as well as the ability to transfer and withdraw funds. We enable consumers to exchange funds more safely with merchants using a variety of funding sources, which may include a bank account, a PayPal or Venmo account balance, PayPal and Venmo branded credit products, a credit card, a debit card, certain cryptocurrencies, or other stored value products such as gift cards, and eligible credit card rewards. Our PayPal, Venmo, and Xoom products also make it safer and simpler for friends and family to transfer funds to each other. We offer merchants an end-to-end payments solution that provides authorization and settlement capabilities, as well as instant access to funds and payouts. We also help merchants connect with their customers, process exchanges and returns, and manage risk. We enable consumers to engage in cross-border shopping and merchants to extend their global reach while reducing the complexity and friction involved in enabling cross-border trade. Our beliefs are the foundation for how we conduct business every day. We live each day guided by our core values of Inclusion, Innovation, Collaboration, and Wellness. Together, our values ensure that we work together as one global team with our customers at the center of everything we do – and they push us to ensure we take care of ourselves, each other, and our communities.
Job Summary: Join PayPal’s Legal team as counsel supporting PayPal-branded US consumer credit products. You will advise teams supporting merchants and partners on the end-to-end distribution and operation of credit products, including sales enablement and marketing. You will also provide legal and regulatory guidance on onboarding, servicing, issue and dispute resolution, and collections for open-end and closed-end consumer credit. This role offers the opportunity to navigate evolving financial services regulation, address matters of first impression, and help business partners deliver innovative credit experiences in a complex regulatory environment.
But note: The instruction: "Do NOT repeat the job title as a heading (the page already shows it) and do NOT put Job ID / requisition numbers as headings — fold minor metadata into a short or drop it." So we can keep Job Summary as a paragraph.
Now Responsibilities:
Responsibilities
- Provide specialized legal advice and support to enable business strategy while identifying and managing legal risk.
- Ensure awareness of and advise on compliance with relevant laws and regulations.
- Build strong partnerships with business counterparts across the enterprise to proactively identify potential legal risks and provide strategic legal guidance.
- Identify, analyze, and advise on potential legal risks, presenting mitigation options and recommendations to protect the company and enable business objectives.
- Escalate complex legal issues and significant risks to senior legal leadership where appropriate.
- Research and analyze new laws, regulations, and regulatory guidance affecting the company's global operations, assessing potential business impact and recommended actions.
- Manage assigned legal matters through resolution, coordinating with internal stakeholders and external counsel as needed.
- Maintain current knowledge of legal developments relevant to assigned business areas and communicate implications.
Requirements:
Requirements
Minimum Qualifications: 5+ years relevant experience and a Juris doctorate degree OR Any equivalent combination of education and experience.
Qualifications:
Qualifications
- Experience advising on legal and regulatory matters involving consumer credit and lending, financial services, consumer protection, sales, contracts, and marketing.
- Strong knowledge of laws and regulations applicable to consumer credit and payments, including UDA
. Additional Responsibilities & Preferred Qualifications: a list of items separated by periods. Let's extract each: - Experience advising on legal and regulatory matters involving consumer credit and lending, financial services, consumer protection, sales, contracts, and marketing. - Strong knowledge of laws and regulations applicable to consumer credit and payments, including UDAAP, EFTA/Reg. E, TILA/Reg. Z, GLBA/Reg. P, FCRA/Reg. V, FDCPA, ECOA/Reg. B, CAN-SPAM, and TCPA. - Experience advising on e-commerce, payments, credit cards, or other consumer and small-business lending products. - Experience supporting regulatory examinations and interactions with regulatory bodies, internal audits, and third-party audits. - Exceptional legal research skills, including analyzing new legislation and regulation and applying evolving requirements to specific business use cases and matters of first impression. - Ability to synthesize complex legal and regulatory requirements and provide clear, practical guidance to stakeholders across different levels of the organization. - Admission to a U.S. state bar and in good standing. - Exceptional legal drafting and writing skills, with strong attention to detail. - Strong communication, collaboration, and problem-solving skills, with the ability to operate effectively in a fast-paced and evolving environment. - Ability to take ownership of complex matters while collaborating effectively with legal colleagues and cross-functional partners across a global organization. We could split into Qualifications and Skills sections. Perhaps Qualifications: the education/experience etc? But we already used Minimum Qualifications for that. Additional Responsibilities & Preferred Qualifications could be split into Qualifications and Skills. However we have headings: Qualifications, Skills. We need to decide what goes where. We could put under Qualifications: items that are about experience/knowledge (like experience advising..., strong knowledge..., experience advising on e-commerce..., experience supporting regulatory examinations...). And under Skills: items like exceptional legal research skills, ability to synthesize..., admission to bar..., exceptional legal drafting..., strong communication..., ability to take ownership... But the instruction: "Prefer a few substantive sections over many thin ones." So maybe we combine Qualifications and Skills into one section? But we have headings list; we can include both if they have content. It's okay to have multiple sections. We need to avoid creating sections with filler. All these items are substantive. Benefits: The paragraph under "Our Benefits:" includes multiple sentences. We'll put as
. Pay: The base pay ranges: we have primary location and additional locations with pay ranges. Also mention additional compensation may include annual performance bonus, equity, or other incentive compensation. We'll include that as prose or list? Could be
. Schedule: The hybrid work model: "For the majority of employees, PayPal's balanced hybrid work model offers 3 days in the office for effective in-person collaboration and 2 days at your choice of either the PayPal office or your home workspace, ensuring that you equally have the benefits and conveniences of both locations." That's schedule. We must not include boilerplate like EEO, scam warnings, etc. Also remove duplicated lines. Now construct HTML. We'll start with
About the role
then include company overview and job summary? Might be too much but okay. Better: About the role: include the company overview (first paragraph) and Job Summary. Could combine. But we need to preserve all substantive information; we can include both. Let's write:About the role
The Company PayPal has been revolutionizing commerce globally for more than 25 years. Creating innovative experiences that make moving money, selling, and shopping simple, personalized, and secure, PayPal empowers consumers and businesses in approximately 200 markets to join and thrive in the global economy. We operate a global, two-sided network at scale that connects hundreds of millions of merchants and consumers. We help merchants and consumers connect, transact, and complete payments, whether they are online or in person. PayPal is more than a connection to third-party payment networks. We provide proprietary payment solutions accepted by merchants that enable the completion of payments on our platform on behalf of our customers. We offer our customers the flexibility to use their accounts to purchase and receive payments for goods and services, as well as the ability to transfer and withdraw funds. We enable consumers to exchange funds more safely with merchants using a variety of funding sources, which may include a bank account, a PayPal or Venmo account balance, PayPal and Venmo branded credit products, a credit card, a debit card, certain cryptocurrencies, or other stored value products such as gift cards, and eligible credit card rewards. Our PayPal, Venmo, and Xoom products also make it safer and simpler for friends and family to transfer funds to each other. We offer merchants an end-to-end payments solution that provides authorization and settlement capabilities, as well as instant access to funds and payouts. We also help merchants connect with their customers, process exchanges and returns, and manage risk. We enable consumers to engage in cross-border shopping and merchants to extend their global reach while reducing the complexity and friction involved in enabling cross-border trade. Our beliefs are the foundation for how we conduct business every day. We live each day guided by our core values of Inclusion, Innovation, Collaboration, and Wellness. Together, our values ensure that we work together as one global team with our customers at the center of everything we do – and they push us to ensure we take care of ourselves, each other, and our communities.
Job Summary: Join PayPal’s Legal team as counsel supporting PayPal-branded US consumer credit products. You will advise teams supporting merchants and partners on the end-to-end distribution and operation of credit products, including sales enablement and marketing. You will also provide legal and regulatory guidance on onboarding, servicing, issue and dispute resolution, and collections for open-end and closed-end consumer credit. This role offers the opportunity to navigate evolving financial services regulation, address matters of first impression, and help business partners deliver innovative credit experiences in a complex regulatory environment.
But note: The instruction: "Do NOT repeat the job title as a heading (the page already shows it) and do NOT put Job ID / requisition numbers as headings — fold minor metadata into a shortor drop it." So we can keep Job Summary as a paragraph. Now Responsibilities:
Responsibilities
- Provide specialized legal advice and support to enable business strategy while identifying and managing legal risk.
- Ensure awareness of and advise on compliance with relevant laws and regulations.
- Build strong partnerships with business counterparts across the enterprise to proactively identify potential legal risks and provide strategic legal guidance.
- Identify, analyze, and advise on potential legal risks, presenting mitigation options and recommendations to protect the company and enable business objectives.
- Escalate complex legal issues and significant risks to senior legal leadership where appropriate.
- Research and analyze new laws, regulations, and regulatory guidance affecting the company's global operations, assessing potential business impact and recommended actions.
- Manage assigned legal matters through resolution, coordinating with internal stakeholders and external counsel as needed.
- Maintain current knowledge of legal developments relevant to assigned business areas and communicate implications.
Requirements
Minimum Qualifications: 5+ years relevant experience and a Juris doctorate degree OR Any equivalent combination of education and experience.
Qualifications:Qualifications
- Experience advising on legal and regulatory matters involving consumer credit and lending, financial services, consumer protection, sales, contracts, and marketing.
- Strong knowledge of laws and regulations applicable to consumer credit and payments, including UDA