Comment to CFPB in Buy Now, Pay Later Inquiry

By U.S. PIRG and Center for Digital Democracy
Last updated: 3/25/2022

The Consumer Financial Protection Bureau (CFPB) asked the public for comments on Buy Now, Pay Later plans. U.S. PIRG filed a joint comment with the Center for Digital Democracy.


Big Tech’s entry into the payments space must be seen as just one of its attempts to take over the broader finance system. Big Tech’s entry poses existential threats to the economy, including to the longtime separation of banking and commerce. The CFPB's press release announcing the orders to five BNPL companies specifically stated its concerns about data harvesting. 

The same “Big Data” driven “surveillance advertising" model that has eroded consumer privacy in most markets, including retail, ecommerce and entertainment, is now being placed within the foundations of the US financial services system. Consumers will be confronted with an “all-seeing” banking and payment system that has gathered and deeply analyzed their information so they can be micro-targeted everywhere online for financial services and applications.

This data harvesting can lead to numerous negative outcomes for consumers. 

Following a section on the implications of the BNPL business model and its role in the new financial “gold rush,” we discuss the findings of U.S. PIRG Education Fund’s new report, “The Hidden Costs of “Buy Now, Pay Later.” U.S. PIRG Education Fund, U.S. PIRG’s research arm, will also file that report as a separate comment in this docket. 

That U.S. PIRG Education Fund report concluded: 

Finally, we maintain our concerns that the vast data collection and monetization engines run by Big Tech firms are designed to fuel an explosion of buying and an increase in consumer debt for stuff we don’t need and can’t afford and, too often, end up throwing away.

We conclude the comment with recommendations to the CFPB to prevent or minimize the threat of negative outcomes for consumers from BNPL.

Resource file download

PDF icon Comments to CFPB on BNPL

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