Consumer Reports and the National Consumer Law Center, on behalf of its low-income comments, submitted comments on the Consumer Financial Protection Bureau’s (CFPB) proposed Interpretive Rule under the Truth in Lending (Regulation Z) on Use of Digital User Accounts to Access Buy Now, Pay Later Loans.
As we described more fully in response to the CFPB’s previous request for information on buy now, pay later (BNPL) credit and in reports on BNPL credit, which we incorporate by reference in these comments, consumers who use BNPL credit face a number of risks. The proposed Interpretive Rule addresses some of those issues. We strongly support the proposed Interpretive Rule, and we also urge the CFPB to take further actions to protect consumers who use BNPL credit.