OCC Issues Policy Guidance on Buy Now, Pay Later Lending
Global Fintech & Digital Assets
DECEMBER 21, 2023
These consumer lending arrangements (also known as “point-of-sale installment loans” or “pay-in-4”) involve short-term installment loans repayable in four or fewer payments and carry no finance or interest charges. BNPL Loans As described in the Guidance, a BNPL arrangement generally involves a bank, a merchant, and a consumer.
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