The Office of the Comptroller of the Currency (OCC) issued guidance (Bulletin 2023-37) (Bulletin 2023-37) on December 6, 2023, that applies to all national banks and federal savings associations concerning management of risk associated with “buy now, pay later” (BNPL) lending. While the stated aim of this guidance is to ensure that BNPL loans are offered in a manner that is safe and sound, the clear emphasis is on consumer protection in that the focus is on providing fair access to financial services, supporting fair treatment to consumers and complying with applicable laws and regulations. 

Read “Office of the Comptroller of the Currency issues ‘buy now, pay later’ guidance to banks."


Senior Counsel

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