Comments Due to NAFCU: CFPB - Inquiry Into Buy-Now-Pay-Later Providers
NAFCU would like to highlight the following:
- The notice and request for comment seeks information on BNPL business models and transaction metrics, loan performance metrics, consumer protections, user contacts and demographics, data harvesting, and data monetization.
- This inquiry comes in response to intense growth in the BNPL market and the information gathered is intended to help the Bureau better understand how consumers interact with BNPL providers, and how BNPL business models impact the broader e-commerce and consumer credit marketplaces.
- The Bureau has indicated that it will not pursue enforcement, supervisory, or rulemaking actions as a result of this inquiry. The Bureau has also expressed interest in potentially reviewing account data from depository institutions to better understand proliferation of BNPL.
Comments due to NAFCU: February 25, 2022
Comments due to CFPB: March 25, 2022
NAFCU will send comments on behalf of its members to CFPB by their deadline (March 25, 2022).