The 90 undersigned consumer, civil rights and community organizations and academics submit these comments on the Consumer Financial Protection Bureau’s Interpretive Rule regarding buy now pay later (BNPL) credit. We support the CFPB’s conclusion that accounts used to access BNPL credit are credit cards that must comply with credit card rules governing disputes, errors, periodic statements and disclosures. Those protections will enhance the safety of BNPL credit and make it easier for consumers to manage their finances.
However, consumers still face the risk of becoming over-indebted and paying costly fees on credit that is supposedly free. Low-income and financially vulnerable consumers, women, Black, and Latino consumers are especially likely to make a purchase using BNPL. We urge the CFPB to go further and to require BNPL providers to comply with other protections required for credit cards, including ability to repay assessments and reasonable and proportional penalty fees.