Policy submission

FCA consultation on Deferred Payment Credit (unregulated Buy Now Pay Later): Proposed approach to regulation - Which? response

Which?'s response to the FCA's proposed approach for regulation of Deferred Payment Credit (unregulated Buy Now Pay Later)
1 min read
Tony HerbertSenior Policy Adviser
  • Regulation remains urgently needed. 
  • We support the overall regulatory approach set out by the FCA. 
  • Merchant-provided DPC must be carefully monitored and brought into regulation by HMT if it becomes more prevalent. 
  • It is not appropriate to rely solely on the Consumer Duty to regulate DPC. Some prescription stands to benefit DPC firms and consumers.
  • We agree the FCA should set out new rules specifying the product information that must be supplied to a consumer before they enter a DPC agreement. 
  • The FCA should be more prescriptive about communications sent to consumers who have missed a repayment. 
  • The regulatory regime developed for DPC should inform reform of the Consumer Credit Act (CCA) but should not be regarded as a blueprint. 
  • The FCA should be alive to potential wider consequences of the DPC regime.
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