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The Consumer Financial Protection Bureau released frequently asked questions to help industry participants understand, implement, and comply with the requirements in Regulation Z for “buy now, pay later” products.
ICBA View: ICBA in July called on the CFPB to ensure BNPL products adhere to the same consumer error-resolution procedures as banks. ICBA said it supports the CFPB position that BNPL digital user accounts are credit products and should comply with relevant sections of Reg Z, including credit disclosures and billing disputes.
Background: BNPL products operate in a space where a consumer’s main avenue of error resolution is through their community bank, and debit and credit card disputes and chargebacks are at record levels.
Previous ICBA Comments: ICBA has consistently called for greater parity between nonbank BNPL providers and more traditional credit products. In a 2022 comment letter, ICBA called on the CFPB to incorporate BNPL products into a regulated ecosystem and provide for consumer disclosures and protections on par with the Truth in Lending Act.