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📢 Treliant Takeaway: New CFPB Rule for BNPL Lenders Earlier this week, the Consumer Financial Protection Bureau issued an interpretive rule classifying Buy Now, Pay Later lenders as credit card providers, extending key legal protections under TILA Reg Z. As BNPL usage rises alongside consumer complaints and defaults, lenders must now investigate disputes, process refunds, and provide billing statements akin to credit card providers. Sabrina Morrison details what this means for financial institutions, including bank partners and fintechs, and what they should be doing to comply with the enhanced requirements in our latest Treliant Takeaway. Treliant offers expert regulatory compliance consulting to help financial institutions navigate these changes. Stay ahead with Treliant! #RegulatoryCompliance #BNPL #FinancialServices

"On May 22, 2024, the Consumer Financial Protection Bureau (CFPB) issued an interpretive rule that redefines the regulatory framework for Buy Now, Pay Later (BNPL) lenders, aligning them with traditional credit card providers subject to the Truth in Lending Act (TILA). This development represents a pivotal shift as most BNPL products had not previously been subject to the comprehensive requirements of TILA." Read the latest Consumer Financial Services blog from Ross Speier, Tatum Andres, and Hannah Koepke here: https://lnkd.in/eXjbTnAB

Consumer Financial Protection Bureau issued an interpretive rule that may impact your consumer products. The first statement is "lenders that issue digital user accounts [viewed as being akin to "credit cards"] that consumers use from time to time to access credit products to purchase goods and services are 'card issuers'" and must comply with certain #TILA requirements. This rule applies even though this product/service is not a true open-end credit. Such service is increasing through #fintech relationships. Even if the BNPL arrangement does not impose a finance charge and is not payable in accordance with a written agreement in more than 4 installments, the CFPB classifies this situation as being #RegulationZ credit. The CFPB is getting involved due to concerns related to #protectedconsumer classes, payment processing and #fees.

Just in: The Consumer Financial Protection Bureau (CFPB) issued an interpretive rule that confirms that Buy Now, Pay Later (BNPL) lenders will typically be deemed credit card providers. Accordingly, BNPL lenders would be required to provide consumers some key legal protections and rights that apply to conventional credit cards, such as dispute and refund rights, billing statements, and disclosures that lay out fees and pricing structures. This is not a big surprise as the CFPB has long hinted that BNPL products should receive many of the same consumer protections applicable to credit cards. The interpretive rule is effective 60 days after publication in the Federal Register. Comments will be accepted until August 1, 2024. https://lnkd.in/e7_ZVfeA #cfpb #bnpl #regulations #regulatorycompliance #fintech #fintechs #financialservices #financialinstitutions #consumerfinance

In case you missed it, the CFPB released its anticipated BNPL as a credit card FAQs. If you want to jump straight to which Reg Z rules the CFPB thinks are required, skip to FAQ 4 of the "Coverage" section. Of course, actual implementation of these requirements is another story...

Our Guidehouse Financial Services colleagues discuss the recent Consumer Financial Protection Bureau “Use of Digital User Accounts to Access Buy Now, Pay Later (BNPL) Loans” interpretive rule. Get in touch with our experts who can collaborate with your teams to facilitate #compliance and manage regulatory risk.

Our Guidehouse Financial Services colleagues discuss the recent Consumer Financial Protection Bureau “Use of Digital User Accounts to Access Buy Now, Pay Later (BNPL) Loans” interpretive rule. Get in touch with our experts who can collaborate with your teams to facilitate #compliance and manage regulatory risk.

Our Guidehouse Financial Services colleagues discuss the recent Consumer Financial Protection Bureau “Use of Digital User Accounts to Access Buy Now, Pay Later (BNPL) Loans” interpretive rule. Get in touch with our experts who can collaborate with your teams to facilitate #compliance and manage regulatory risk.

Our Guidehouse Financial Services colleagues discuss the recent Consumer Financial Protection Bureau “Use of Digital User Accounts to Access Buy Now, Pay Later (BNPL) Loans” interpretive rule. Let's collaborate to facilitate #compliance and manage regulatory risk.