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.
Published
2024/05/30