Last month, the Consumer Financial Protection Bureau (CFPB) issued orders to five companies offering buy now, pay later (BNPL) products, asking them to provide information on several topics, including:

  • Business models,
  • BNPL performance metrics,
  • Disclosures and other consumer protections,
  • User demographics, and
  • Data harvesting and monetization.

For more information the CFPB’s inquiry, please see our post covering those orders here.

On January 24, the CFPB issued a notice and request for comment on its BNPL inquiry. The notice seeks comments from any interested parties about BNPL products and provides the following examples of information the CFPB seeks:

  • What is the consumer experience with BNPL products?
  • What are the benefits and risks to consumers from BNPL products?
  • What is the merchant experience with BNPL products?
  • What perspectives do regulators and attorneys general have with respect to BNPL products?
  • Are there ways in which the BNPL market can be improved?

For more information about the notice and request for comment and BNPL generally, the CFPB wrote a blog post in conjunction with the notice.

Comments must be received on or before March 25, 2022.