OCC Issues Policy Guidance on Buy Now, Pay Later Lending
Global Fintech & Digital Assets
DECEMBER 21, 2023
Long , Parag Patel , Barrie VanBrackle , Becky Critchley , Deric Behar , and Charlotte Collins On December 6, 2023, the Office of the Comptroller of the Currency (OCC) issued Bulletin 2023-37 (Guidance), which clarifies the OCC’s policy positions on the risk management of “Buy Now, Pay Later” (BNPL) lending. By Arthur S.
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