CFPB Issues Interpretive Rule on Buy Now Pay Later Loans

The CFPB has issued an Interpretive Rule that states lenders that issue digital user accounts that consumers use from time to time to access credit products to purchase goods and services are “card issuers” under Regulation Z, including when those products are marketed as Buy Now, Pay Later. As a result, they are also “creditors” for purposes of Regulation Z regardless of whether the credit is subject to a finance charge or payable by written agreement in more than four installments.

If you feel this may impact you, we encourage you to take a close look at the Rule. It is effective 60 days after being published in the Federal Register, but comments are being accepted through August 1st.

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Diane Dean

Diane joined Banker’s Compliance Consulting with over 10 years of compliance experience and over 15 years of experience within the financial industry. Diane is a Certified Regulatory Compliance Manager (CRCM) and has a Bachelor’s Degree in Sociology with a concentration in Criminal Justice. She is a graduate of the Schools of Banking Compliance School and has participated in various other training opportunities throughout her career. Diane understands firsthand the struggles banks face in building and maintaining successful compliance programs. Her experience and common sense approach to consumer compliance is a great asset to our clients. Diane and her husband have two kids who keep them busy. She enjoys running and other sports and is a big Bugs Bunny fan! She’s a bit crazy in that she does enjoy reading some of these regulations and she’s a “crazy cat lady!” Her cat tales are hilarious!

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