On May 22, the Consumer Financial Protection Bureau issued an interpretive rule that has the effect of requiring providers of closed-end buy-now, pay-later credit products to apply certain open-end credit consumer protections from the Truth in Lending Act and its implementing Regulation Z.
These protections include the right to allege transaction disputes, the right to receive paper statements and other disclosures, and the right to a prompt refund when a merchant accepts a return.
The interpretive rule takes effect July 30 and raises several questions about how BNPL providers are expected to comply.
LINKS
Read “Making Plans For BNPL Consumer Protection Compliance” co authored by Tarrian Ellis, and published on Law360.