Truth in Lending (Regulation Z); Use of Digital User Accounts To Access Buy Now, Pay Later Loans

The Consumer Financial Protection Bureau (CFPB) is issuing this interpretive rule to address the applicability of subpart B of Regulation Z to lenders that issue digital user accounts used to access credit, including to those lenders that market loans as "Buy Now, Pay Later" (BNPL). This interpretive rule describes how these lenders meet the criteria for being "card issuers" for purposes of Regulation Z. Such lenders that extend credit are also "creditors" subject to subpart B of Regulation Z, including those provisions governing periodic statements and billing disputes. While not required under the Administrative Procedure Act, the CFPB is opting to collect comments on this interpretive rule and may make revisions as appropriate after reviewing feedback received.