Letter urging CFPB to clarify Regulation Z interpretive rule on Buy Now, Pay Later Loans

ICBA asked the CFPB that BNPL adhere to the same consumer error resolution procedures as banks. Without the CFPB clarifying that Regulation Z consumer protection rules apply, BNPL products operate in a space where consumers’ main avenue of error resolution with providers is through their bank. This interpretive ruling should properly assign consumer protection responsibility to the BNPL providers and prevent disputes between consumers and their community banks regarding payments to BNPL providers.