Joint Comments to CFPB on Buy Now, Pay Later

To Whom It May Concern:

The Center for Capital Markets Competitiveness ("CCMC") and the American Bankers Association ("ABA") appreciates the opportunity to submit comments to the Consumer Financial Protection Bureau ("CFPB") regarding its Interpretive Rule on Truth in Lending (Regulation Z); Use of Digital User Accounts To Access Buy Now, Pay Later Loans (the "Interpretive Rule").

The entrance of Buy Now, Pay Later ("BNPL") products into the financial services market has benefitted consumers. BNPL products offer consumers an additional option in purchasing goods and services. In particular, BNPL products benefit those consumers who lack access to or do not want to use more traditional forms of credit. BNPL products have also introduced further innovation and competition into the marketplace for financial services. However, the novel structure of BNPL products has resulted in some regulatory uncertainty.

The CCMC and ABA accordingly would welcome additional regulatory transparency surrounding BNPL products. This would benefit consumers by clarifying applicable consumer protection requirements, which in turn would promote consistency in those protections across the available BNPL products on the market. Clarifying the regulatory scheme that applies to BNPL products also would help to ensure that BNPL providers are held to standards similar to providers of other consumer financial products and services.

Download the joint comment letter to read the full text.