Buy Now Pay Later options at the till are clearly becoming increasingly attractive to consumers and investors alike. For the consumer, it's quick and easy access to credit. For investors, there's a rapidly growing market to tap into. The Woolard Review estimates that the growth in the value of BNPL transactions during 2020 nearly quadrupled, and Brodies' securitisation team has witnessed that growth through the increasing number of securitisations of BNPL derived consumer receivables that we advise on.

However, a little like the spend now pay later elements of last week's budget, it may pay to keep proposed changes to the current regime front of mind. BNPL products currently benefit from exemptions to FCA regulation, but that is expected to change following the Government's recent announcement that BNPL products will be brought into the FCA's remit in order to protect consumers. It will take time to implement regulatory changes, but the way in which BNPL products are offered and operate will almost certainly be required to change in the coming years. In turn, the changes are likely to have a knock-on impact on securitisations of BNPL derived receivables. Originators and investors looking to enter into such securitisations in the future should be mindful that regulatory changes are on the horizon.

Bruce Stephen and Lindsay Lee discuss the Woolard Review and broader impacts of the Buy Now Pay Later market here. For a reminder of some of the key aspects of securitisations from a Scottish perspective, here is our handy guide.


Peter Brading

Senior Associate

Marion MacInnes

Head of Banking and Finance & Partner