In response to the Request for Comments issued by the Consumer Financial Protection Bureau, Center for Responsible Lending, National Consumer Law Center (on behalf of its low-income clients), and Consumer Federation of America offer our joint recommendations for further guidance and monitoring of the growing BNPL market overall, which are specific to the “pay-in-four” model. Our comment covers substantial background of the BNPL market; considerations based on current consumer protection laws, and concerns we hope the Bureau, within its authority, will address.
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