On September 18, the CFPB
issued Frequently Asked Questions (FAQ) guidance on Buy Now, Pay Later (BNPL) products. The FAQs are organized into three sections: (i) a general description of BNPL products and “Pay-in-Four” BNPL loans; (ii) scope and coverage of Pay-in-Four BNPL loans; and (iii) requirements for periodic statements for Pay-in-Four BNPL loans. In particular, the FAQs offer direction on how to apply Regulation Z to BNPL products, including the application of credit card periodic statement requirements to Pay-in-Four BNPL products accessed through digital user accounts.
As previously covered by InfoBytes, the CFPB issued an interpretive rule in May, stating its position that certain consumer protection provisions of Regulation Z applied to BNPL accounts.
