The American Fintech Council (AFC) has responded to the Consumer Financial Protection Bureau’s (CFPB) proposed Interpretive Rule on the use of digital user accounts to access Buy Now, Pay Later (BNPL) loans. In their response, AFC emphasized the importance of regulatory clarity and consistent standards to ensure that financial services, particularly BNPL loans, remain safe, transparent, and responsible for consumers. AFC CEO Phil Goldfeder praised the CFPB’s efforts to understand the BNPL industry and expressed the organization’s willingness to provide feedback to enhance consumer protection while maintaining competition and innovation.
AFC has developed policy standards for BNPL products, including classifying them as loans, ensuring transparent terms, underwriting transactions at the point of sale, and providing necessary loan disclosures. Additionally, AFC supports improving credit reporting standards. In their letter, AFC applauded the CFPB's 2022 report on BNPL and urged for additional time and clarity to help providers comply with new regulations. AFC's stance aligns with the Truth in Lending Act (TILA) and aims to ensure that nonbank financial companies adhere to the same rules as traditional banks and credit unions. The organization continues to advocate for consumer protection and consistent product experiences in the evolving fintech landscape.
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