Protect Borrowers submitted the following comment to the New York State Department of Financial Services (the Department) in response to its proposed regulations to implement the Buy-Now-Pay-Later Act (BNPL Act).
Protect Borrowers supports the BNPL Act and the Department’s proposed implementing regulations as BNPL products continue to quickly proliferate and evolve, capitalizing on working families’ growing financial desperation. In the comment, Protect Borrowers proposes several ways the Department can strengthen its proposed regulations to effectuate the legislative intent behind the BNPL Act, including ensuring the regulation’s scope is as broad as the Act’s, clarifying what constitutes “interest” for a BNPL loan, and strengthening data protection provisions.
Read the Comment: Comment to New York State Department of Financial Services on Proposed Regulations to Implement the Buy-Now-Pay-Later Act