In most cases a fintech cannot lend its own funds to the public as a business without an appropriate licence. Lending is generally carried out by banks, finance companies or microfinance institutions licensed by the Microcredit Regulatory Authority, each under its own framework. Most fintechs therefore partner with a licensed lender, providing technology, customer acquisition, scoring support and servicing, while the lender makes and holds the loans. The partnership must be structured so that regulated activities remain with the lender. We review each model carefully, because the line between service provider and unlicensed consumer credit provider is easily crossed.

Bangladesh Bank has permitted banks to offer small digital loans, often called nano loans, through digital channels including mobile financial services wallets, under specific published guidance on eligibility, limits, tenor, credit scoring, disbursement, repayment and customer protection. The bank remains the lender and is responsible for compliance, while the wallet provider and any technology partner support distribution and servicing under contract. We advise banks, mobile financial services providers and fintechs on structuring nano loan programmes, partnership agreements and data flows in line with current guidance, which has evolved considerably since the first programmes were launched.

There is no single dedicated buy now pay later regime, so the analysis depends on the structure. If a bank or finance company provides the credit, its consumer financing rules apply. If a merchant or platform offers deferred payment itself, the arrangement may amount to lending that requires a licence, especially if fees or interest are charged or the activity is carried on at scale. E-commerce rules and consumer protection law also apply to how the offer is displayed. We review proposed buy now pay later models and recommend structures, usually through a licensed lender, that are workable and compliant.

Customers should receive clear written information on the interest or profit rate, all fees and charges, the total amount payable, repayment schedule, consequences of late payment and how to complain, before they commit. Bangladesh Bank requirements for banks and finance companies, and consumer protection law more generally, support transparent disclosure, and hidden or unclear charges attract complaints and regulatory attention. Digital journeys need particular care and testing, because key information can be buried in screens customers skip. We help lenders design key facts statements and consent flows that are accurate, concise and easy to understand.

Alternative data can support credit decisions for customers without a traditional credit history, but its use must comply with the Personal Data Protection Act 2026 and the terms under which the data was collected. Lenders and partners need a lawful basis, usually clear and specific consent, for using and sharing the data for scoring, and must limit use to stated purposes and protect it securely. Customers may also have rights to access and correct their data. We advise on consent wording, data sharing agreements and governance of scoring models, so that consumer credit underwriting remains both effective and lawful.

Lenders may pursue repayment through reminders, contact with the borrower, restructuring and, where necessary, legal action, but practices that harass, threaten, shame or mislead borrowers, contact third parties inappropriately or misuse personal data create legal and regulatory risk. Bangladesh Bank has expected banks to supervise recovery agents and treat customers fairly, and data protection law limits how contact information can be used. We prepare written collection policies, agent agreements and training materials that set clear standards, and advise on recovery routes for defaulted loans, including court proceedings. Complaint logs and agent audit trails help show collection conduct was fair.

Investors should first confirm who holds the licence for each activity, whether the partnership agreements allocate regulated functions correctly, how pricing, disclosures and collections comply with current rules, how customer data is collected and shared, whether any regulator has raised concerns and how loan losses are funded and reported. Heavy dependence on a single bank or wallet partner is a commercial and regulatory risk. We conduct focused regulatory due diligence on consumer credit businesses and translate findings into conditions, warranties, indemnities and compliance plans. Findings should be raised before signing, so that price and warranties reflect any licensing gap.

Disputes in consumer credit partnerships typically concern revenue sharing, loan losses, data ownership, exclusivity, performance standards or termination. Partnership agreements should set out clear dispute resolution procedures, including escalation, mediation and arbitration or court jurisdiction, and should address what happens to customers, data and outstanding loans if the relationship ends. Regulators may also need to be informed if a partnership affecting customers changes. We advise lenders and platforms on negotiating and enforcing these provisions, and represent clients in disputes, with the aim of protecting customers and continuity of service while preserving each party's commercial position.