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        Consumers who are scraping by and those who are
        financially stable are drawn to the repayment terms and        I suspect many of these are
        budgeting benefits, as well as the low-cost of using BNPL,   the same merchants who balk at
        J.D. Power explained. In fact, the firm found consumers
        from across the "financial health spectrum" are happy         paying 2 percent to 4 percent
        users of BNPL, and all are drawn by the same primary
        reason: "they like the repayment terms."                  per transaction in card interchange.
        Washington weighs in                                        But that's a different discussion
                                                                             for a different day.
        Still, there is considerable consternation around BNPL. The
        Consumer Financial Protection Bureau, not surprisingly,
        raised concerns over what it sees as inconsistent
        consumer protections and the risk of consumers getting   intended to be glossy, tech-savvy alternatives to
        overextended. Lawmakers have taken notice, too. In early   traditional loan products without adhering to the robust
        November a House Financial Services subcommittee held   consumer protection laws and regulations in place for
        a hearing on the risks and benefits of BNPL and other   banks and credit unions," CUNA wrote in a statement to
        emerging fintech cash flow products.                    the subcommittee.

        The Credit Union National Association, a credit union   As we look to 2024, it's a safe bet we'll be hearing more
        trade group, was among those urging lawmakers to lay    from Congress and the CFPB on this
        down some regulatory guardrails, like those credit unions   topic.
        and banks must operate within.
                                                                Patti Murphy, self-described payments maven of the fourth estate, is
        "CUNA remains concerned that the vast majority of       senior editor at The Green Sheet. She also co-hosts the Merchant Sales
        BNPL providers remain unregulated and are increasingly   Podcast and is president of ProScribes Ink (www.proscribes.net).
        engaged in financial activities by offering products





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