December 21, 2021 — Letter

The undersigned 79 consumer, housing, civil rights, legal services, faith, community, small business, and financial organizations groups would like to thank you for your recent inquiry into buy now, pay later providers, and write to urge you to carefully examine these and other fintech credit products and fee models. New consumer credit products are exploding across market areas, including but not limited to buy now, pay later (BNPL) loans, income share agreements, cash advances, “fintech” overdraft or overdraft avoidance products, and earned wage access products or look-alike products. Although innovation has an important role in the financial marketplace, it should be pursued in a way that is consistent with and enhances consumer protections. It should not shield new products from consumer protection laws and oversight. Although some of these credit products could help consumers manage their finances, they are
certainly not risk-free.