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ARTICLE · 13 DECEMBER 2023

OCC Issues Guidance On Risk Management Of "Buy Now, Pay Later" Lending

Goodwin Procter LLP
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In this Issue. The Office of the Comptroller of the Currency (OCC) issued a bulletin to assist banks in effectively managing risks associated with "buy now, pay later" lending...

United StatesTechnology
Goodwin Procter LLP
Goodwin Procter LLP

In this Issue. The Office of the Comptroller of the Currency (OCC) issued a bulletin to assist banks in effectively managing risks associated with "buy now, pay later" lending; the Federal Deposit Insurance Corporation (FDIC) extended the comment period for proposed addition of Appendix C to part 364 of the FDIC's rules and regulations; the OCC solicited research on depositor behavior, bank liquidity, and run risk; and the Consumer Financial Protection Bureau (CFPB) expressed its support for the California Department of Financial Protection and Innovation's (DFPI) treatment of income-based advances like loans. These and other developments are discussed in more detail below.

Regulatory Developments

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