An analysis of BNPL-specific consumer complaints submitted to the CFPB and the compliance risks they present
According to the CFPB, consumers’ complaints provide valuable information about the types of challenges consumers are experiencing in the marketplace and the effectiveness of an organization’s compliance management system.
By being aware of the types of issues that consumers are complaining about, organizations can use this information to shape their compliance programs to focus on the most pressing issues presenting risk to their business.
Here are the top consumer complaint trends that BNPL companies should know to mitigate compliance risk.
Please note: The consumer complaint database does not yet have a product category for BNPL. To get these insights, we searched consumer complaint narratives for BNPL keywords— including variations of BNPL, buy now pay later, installment loans, and pay in four—and filtered complaints submitted against companies who exclusively offer BNPL products.
Since January 2022, there have been over 8k BNPL-related complaints in the CFPB's Consumer Complaint Database.
Complaints related to BNPL products vary monthly, but there is a noticeable upward trend in the overall number of complaints over time.
The top 5 issues reported by consumers make up 78% of all complaints about BNPL products, primarily around inaccurate credit reporting, unexpected fees, difficulties in making payments, challenges when securing loans, and struggles with loan repayments.
When analyzing consumer complaint narratives, the words that appeared most often are credit, account, report, loan, payment, and information. This suggests that the most common concerns among consumers are related to credit-related matters, reporting inaccuracies, loan issues, payment problems, and the accuracy of provided information—all of which further confirms the top issues as reported by consumers in the previous chart.
While the volume of BNPL-related complaints might fluctuate over time, a notable upward trend in overall complaints signals a growing concern among consumers. With the top 5 reported issues centered around credit reporting, unexpected fees, payment difficulties, loan acquisition, and repayment struggles—BNPL providers should pay heed to these evolving concerns to enhance the consumer experience and ensure compliance.
As the landscape of BNPL complaints evolves, providers should be prepared to adapt. An increased focus on transparent communication regarding terms, fees, and payment processes can help streamline the payment experience and avoid misunderstandings that lead to complaints. Additionally, offering support and resources for customers facing financial challenges is crucial to addressing the rising concerns related to payment difficulties and loan repayments.
BNPL providers should implement proactive compliance monitoring mechanisms to detect potential issues before they escalate to regulatory concerns. Regularly monitoring various communication channels, including merchant web pages, social media, and other consumer communication channels, can help providers identify emerging complaints or compliance issues and address them swiftly.
Ensuring all marketing and sales communications with your consumers are compliant and transparent is critical to building trust.
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With PerformLine, organizations like yours can monitor all of its marketing channels and affiliate partners at scale to better protect consumers and avoid the complaints that lead to investigations & enforcement actions by the CFPB.