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# CFPB Classifies Buy Now Pay Later Products as Credit Cards Under Truth in Lending Act
- URL: https://www.theglobalbanker.com/cfpb-classifies-buy-now-pay-later-credit-cards-truth-in-lending-act-2024/
- Published: 2024-05-22T12:28:00.000Z
- Updated: 2026-10-02T14:45:40.000Z
- Description: The CFPB issued an interpretive rule on 22 May 2024 treating BNPL accounts as credit cards, requiring providers to issue billing statements and handle disputes.
- Author: TGB Editorial Team
- Tags: Regulations, Americas, #archive

The Consumer Financial Protection Bureau issued an interpretive rule on 22 May 2024 classifying Buy Now Pay Later products as credit cards under the Truth in Lending Act and its implementing regulation, Regulation Z. The rule establishes that lenders offering BNPL facilities — which allow consumers to divide purchase costs into a series of instalments, typically without interest — must comply with the same disclosure, billing, and dispute-resolution obligations that have long applied to traditional credit card issuers.

The interpretive rule does not require new legislation; rather, it sets out the CFPB's reading of how existing law already applies to BNPL products. 

#### BILLING, DISPUTES, AND REFUND RIGHTS NOW REQUIRED

Under the interpretive rule, BNPL providers are required to issue periodic billing statements to customers, mirroring the monthly statements that credit card holders receive from their card issuers. They must also establish and maintain processes to investigate consumer disputes — including cases where a merchant fails to deliver goods or a charge is contested as unauthorised — and provide refund rights consistent with those available to credit card users. 

The CFPB has indicated that its supervisory attention has been drawn to the sector by the rapid growth in consumer uptake and by complaints received from borrowers experiencing difficulties with refunds and disputes.