Apologies if this has already been covered elsewhere, but I couldn't find the answer in a search.

I have a client offering a BNPL transaction type that's not tied to a debit or credit card, but it follows a pretty standard model of applying for the credit at checkout. Where I'm struggling a bit is cases where they are notified of fraud: the person with this loan in their name is NOT the person who made the purchase. My client maintains that the Reg Z billing error resolution rules do not apply, because § 1026.12 & § 1026.13 are both contained within subpart B, which is for open-ended credit. These accounts are paid back in 6 months, so they're closed-ended, and subpart C has no section on error resolution. They're also not concerned about FCRA rules, because these accounts are not reported to the credit bureaus.

I'm vehemently against treating these accounts as having no protection whatsoever. I've looked through everything I can think of, including the OCC Risk Management bulletins, but I can't find anything that references what error resolution rules (if any) need to be followed. Is there anything I can point to in support of treating these similarly to Credit Card disputes, or am I just wrong?

Many thanks.

So, what you are saying is that there has been identify theft? Therefore, there is no valid contract for repayment.