CFPB seeking public comment on buy-now-pay-later products

Ballard Spahr LLP

Ballard Spahr LLP

Having sent orders last month to five companies that offer buy-now-pay-later (BNPL) products directing them to provide information to the Bureau, the CFPB published a notice in today’s Federal Register seeking public comment to inform its inquiry into BPNL products.  Comments must be filed by March 25, 2022.

In a blog post about the request for comments, the CFPB indicated that “some analysts have suggested that BNPL has rerouted big holiday shopping money away from the credit card companies towards these companies, putting an enormous amount of consumer debt on their books.”  As it did when the orders were issued last month, the CFPB raised its concerns with “some systemic, underlying problems, particularly around accumulating debt, regulatory arbitrage, and data harvesting in a consumer credit market already quickly changing with technology.”  It also observed that regulators in other countries have taken an active interest in BNPL.

In the Federal Register notice, the CFPB states that it “encourages comments about BPNL products” and gives the following examples of issues:

  • What is the consumer experience with BNPL product?
  • What are the benefits and risks to consumers from BNPL products?
  • What is the merchant experience with BNPL products?
  • What perspectives do regulators and attorneys general have with respect to BNPL products?
  • Are there ways in which the BNPL market can be improved?

[View source.]

DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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