Primary Dataset: CFPB Consumer Complaint Database
The primary dataset is the CFPB Consumer Complaint Database, a publicly available repository of consumer complaints regarding financial products and services. Complaints are submitted by consumers directly and forwarded to the relevant company for response. The database includes structured fields (complaint type, company response, timeliness of response) as well as unstructured consumer-authored narratives, which are included when the consumer provides consent.
Source: CFPB Consumer Complaint Database
Scope and Coverage
The analysis focuses on complaints filed against Affirm Holdings, Inc. and Klarna AB, the two largest BNPL providers in the U.S. market, covering the period from January 2023 through April 2026. This window captures the period of significant BNPL market expansion documented in CFPB market reports [1] and encompasses the period during which the CFPB’s interpretive rule was issued and contested.
The final dataset contains 13,396 complaints:
| Affirm Holdings, Inc. |
11,755 |
| Klarna AB |
1,641 |
| Total |
13,396 |
Narratives with consumer consent: 4,791 (36% of dataset).
Regulatory Documentation
For the regulatory gap analysis, three categories of primary source documentation are used.
TILA / Regulation Z Requirements
TILA and Regulation Z requirements are drawn from the Code of Federal Regulations (12 CFR Part 1026), specifically provisions:
| §1026.6 |
Account-opening disclosures |
| §1026.7 |
Periodic statements |
| §1026.13 |
Billing error rights |
| §1026.60 |
Credit card application disclosures |
| §1026.51 |
Ability-to-pay assessment |
Affirm Disclosure Practices
Klarna Disclosure Practices