Last week we saw the Financial Conduct Authority (FCA) issue a Press Release warning Buy Now Pay Later (BNPL) firms about misleading adverts. 

There is certainly a lot of scrutiny and discussion about the BNPL sector with controversy over recent initiatives, including BNPL for food and rapid expansion in retail propositions that often target a younger, less financially sophisticated consumer than Bumper’s target market in the automotive sector. 

Given the cost-of-living crisis it is right that firms fully explain the risks associated with BNPL agreements to ensure that consumers fully understand the potential risks versus the obvious benefits. 

The FCA clearly has concerns in these areas, and its release, unusually, takes care to provide examples of how a firm may test if adverts are clear, fair and not misleading.  

This is very helpful to ensure all BNPL firms are consistent in applying the same benchmark to advertising as we do at Bumper. 

So, what are the examples and how do we meet the standards now at Bumper: 

The risk of taking on debt that customers cannot afford to repay, the consequences of missed payments and any other adverse consequences such as the impact on the customer's credit file. 

We clearly explain that a soft search is undertaken upon application, and that it does not impact a customer's credit score, but any missed payments may in the future affect their ability to borrow. (*See our up-to-date risk warning below) 

Information about when charges become payable   

We have always been extremely clear about our product; keeping it simple, 0% interest and a one-off fee of £12 for the first instance of a repayment being missed by 7 days or more. That’s it, no hidden charges or penalties. 

All our advertising follows the FCA’s guidance, we do not use Social Media influencers, and ensure we approve all adverts - be they real time, static or social media posts from Bumper. 

We took the step earlier in the year (January) to recruit a Chief Risk & Compliance Officer, Paul Edgecombe, who has 30+ years' experience in financial services and specific experience in Financial Promotions as SM16/17 approved by the FCA. Paul oversees our advertising and has set robust controls to ensure the standards are what you would expect from a regulated firm in advance of the forthcoming regulation of BNPL. 

The FCA has suggested all BNPL firms that are currently unregulated and operating under exemptions check with their legal teams to ensure they remain exempt from requiring an FCA authorised firm approving their advertising. We are confident that all our advertising is compliant but to prove this is the case, we have asked for this clarification in line with the FCA’s request. We expect to hear from them very soon and will of course update all our partners once advice is received. 

For now, we welcome the FCA’s guidance and believe the forthcoming regulation in the BNPL sector will be a positive for consumers at a time when they may be most vulnerable. All our efforts this year have been made to demonstrate Bumper meets not only the FCA’s standards on Financial Promotions but all the rules and guidance they would expect from a regulated BNPL lender. 

*Bumper Risk Warning 

PayLater is a form of credit not regulated by the FCA. Missed payments may impact your credit score and your ability to borrow in the future.  A one-off missed payment fee (£12) may be charged. Recovering missed payments may involve using a debt collection agency, or legal action. T&Cs apply.