Responding To CFPB Demands For Electronic Data: Key Tips

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By Jyothi Nagarajan, Shawn McGrath and Jack Cobb (March 24, 2022, 6:13 PM EDT) — The Consumer Financial Protection Bureau has recently cited concerns about accumulating debt, regulatory arbitrage and data harvesting in regard to “buy now, pay later” financing.[1]

The CFPB has subsequently begun to address these concerns by sending inquiries to some of the most prominent providers of buy now, pay later financing, with interest in their business models, consumer protections, monetization of customer data and other issues.

The examination of such financing arrangements is part of the CFPB’s recently heightened enforcement posture, and its increasingly vigilant protection of consumers. The CFPB, which has responsibility under the Dodd-Frank Act to enforce a wide range…

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