March 25, 2022 — Comments

In response to the Request for Comments issued by the Consumer Financial Protection Bureau, Center for Responsible Lending, National Consumer Law Center (on behalf of its low-income clients), and Consumer Federation of America offer our joint recommendations for further guidance and monitoring of the growing BNPL market overall, which are specific to the “pay-in-four” model. Our comment covers substantial background of the BNPL market; considerations based on current consumer protection laws, and concerns we hope the Bureau, within its authority, will address.