On June 30, Foundation Partners Group announced a partnership with a financial technology company called Lilypay. The pitch is simple. Families who cannot pay for a funeral up front can split the cost into four payments over three or six months. The funeral home gets paid the same day. The family pays later.
Foundation Partners serves more than 125,000 families a year across roughly 230 locations in 21 states. A financing product placed inside that many arrangement rooms is not a pilot program. It is infrastructure.
The lender's own website markets the plans as "0% interest ever." The same page lists the actual cost. Lilypay charges a "service fee" of 4 percent for a three-month plan and 8 percent for a six-month plan. An $8,000 funeral financed over six months carries a $640 fee, according to the company's payment calculator. Longer terms cost more. That is the economic behavior of interest, presented under a different name.
By the Numbers
Buy-now-pay-later arrived in retail years ago. Affirm, Klarna, Afterpay, and PayPal built a multibillion-dollar industry by letting shoppers split purchases into installments, usually with no hard credit check. The catch was always in the fee structure, and the regulatory fight followed.
In May 2024, the Consumer Financial Protection Bureau finalized a rule treating BNPL lenders as credit card issuers under the Truth in Lending Act. The rule, published at 89 Federal Register 47,068, required these lenders to investigate billing disputes, issue refunds, and send periodic statements. It was the first federal attempt to pull the category under traditional lending disclosure rules.
Thirteen months later, the same bureau walked it back. On May 6, 2025, the CFPB announced it would "not prioritize enforcement actions" under the BNPL rule and said it was "contemplating taking appropriate action to rescind" it entirely. The agency redirected its enforcement and supervision resources toward cases involving servicemembers and veterans. The rule remains technically on the books. The will to enforce it does not.
The CFPB's own data page tracking buy-now-pay-later lending trends, which previously provided public data on BNPL volume and borrower demographics, is no longer accessible. As of July 1, 2026, the page at consumerfinance.gov returns a 404 error. The bureau's 2022 BNPL report, which covered the five largest retail BNPL lenders, never included funeral-specific products. Lilypay, founded in 2024, has never been included in any federal BNPL data collection.
How the funeral installment plan works
Lilypay, founded in 2024 and headquartered in the United States, was built specifically for funeral and cemetery financing. Its model mirrors the retail BNPL playbook, adapted for the arrangement table.
A family fills out a brief online application. Lilypay runs a soft credit review, which does not affect the applicant's credit score. If approved, the family makes one initial payment. The remaining balance splits into three more payments, debited automatically over the chosen three- or six-month window. Lilypay sends payment directly to the funeral home through same-day ACH transfer.
The structure has a feature the marketing does not emphasize. Lilypay assumes the repayment risk. If a family defaults, the funeral home has already been paid. Foundation Partners collects the full amount up front and carries none of the credit exposure. That risk sits with Lilypay, or with whichever party is funding Lilypay's loans.
For the funeral provider, the pitch is straightforward. Will Swaney, Foundation Partners' vice president of product, said the partnership "gives our funeral directors another practical tool." In the announcement, he framed it as reducing barriers to care. The same statement noted that participating funeral homes benefit from "same-day ACH funding, reduced credit card processing costs and minimal administrative burden." The funeral home gets paid the same day and pays lower card fees. It also sheds the risk of families who cannot settle the bill, because that obligation now belongs to the lender.
"No interest ever" and the fee that scales with time
Lilypay's "How It Works" page presents a comparison table. The table lists the company's plans against credit cards and personal loans. Under interest rate, Lilypay's row shows a checkmark next to "0% Interest." The credit card row shows "15-30% APR." The personal loan row shows "6-36% APR."
The page does not list an APR for its own product. It lists a service fee instead. Four percent for three months. Eight percent for six months. A late payment costs $25, with a 24-hour grace period.
The distinction between a fee and interest is not just semantic. Under the Truth in Lending Act, "interest" and "finance charges" trigger mandatory disclosure of the annual percentage rate. That APR disclosure is what lets a borrower compare the real cost of a credit card against a personal loan against a BNPL plan. A flat "service fee" that is not classified as a finance charge can sidestep that requirement. The CFPB's 2024 rule was written to close exactly this loophole for digital BNPL products. The agency then declined to enforce it.
The fee's own structure gives away the game. A family that needs three months to pay is charged 4 percent. A family that needs six months is charged 8 percent. The cost doubles when the repayment window doubles. That is how interest is priced. Lilypay's marketing calls it something else.
Phillip Mason, Lilypay's co-founder and chief executive, said in the announcement that he "sat with families making impossible financial decisions while grieving." His company's payment calculator shows an $8,000 funeral financed over six months costing $8,640 once the fee is included. For a family already stretched by an unexpected death, that $640 is the price of spreading the cost over half a year.
"Soft pull" marketing and the credit reporting contradiction
Lilypay's homepage tells families the application involves a "soft pull, no impact on score." That language refers only to the application process. The company's own Installment Agreement tells a more complete story.
Section 9 of the agreement, titled "Credit Reporting," states: "Lilypay may report payment history to credit bureaus. Positive payment history can help build your credit score, while missed payments may negatively impact your credit." Section 4 covers default terms: "If payments are more than 30 days past due, the account may be considered in default."
A family reading the homepage sees "no impact on score." A family who misses a payment after a funeral may discover that the lender can report that delinquency to credit bureaus. The marketing language and the contractual language describe different things. The first describes the application. The second describes the repayment. Families approaching a funeral are unlikely to read the installment agreement before signing.
Who carries the risk, and who collects the fee
The arrangement shifts credit risk away from the funeral home entirely. Foundation Partners is paid in full on the day of the arrangement. The repayment obligation belongs to the family. The default risk belongs to Lilypay.
That separation matters because it changes how the funeral home sells the service. A director who once had to worry whether a family could actually pay the bill no longer carries that concern. The financing tool removes the incentive to discuss affordability, because the transaction is settled before the family leaves the room. The conversation about whether a family can afford a particular casket or service package becomes less fraught for the business. It does not become less expensive for the family.
Lilypay already operates with at least one other deathcare partner. Customer testimonials on its website reference after.com, a direct cremation provider. The Foundation Partners deal is the company's largest distribution channel to date, placing its product inside a chain that serves 125,000 families annually.
The transparency gap
No federal or state agency tracks defaults on funeral-specific installment plans. The CFPB, which has jurisdiction over consumer lending, removed its own BNPL data page from its website. Lilypay is a private company with no public disclosure obligations. The result is that the most basic questions about this product cannot be answered.
How many families default? Unknown. No agency collects the data. How many families fall behind on payments and face collection actions? Unknown. The Lilypay installment agreement says the company "will work with you to establish a payment plan before taking any collection actions," but there is no public record of how often collections occur or what "working with you" means in practice. Can funeral BNPL debt be discharged in bankruptcy? Yes, as unsecured debt in Chapter 7 or Chapter 13. But bankruptcy filings do not categorize debt by purchase type, so no one knows how many bankruptcy cases include funeral financing.
The absence of data is not accidental. It is the product of a regulatory structure in which the agency charged with consumer lending enforcement has walked away from the category, the agency charged with funeral industry oversight has no jurisdiction over lending, and the lender itself has no obligation to disclose.
The regulatory gap, and who benefits from it
No federal rule specifically governs a financing product embedded inside a funeral arrangement. The FTC Funeral Rule, last substantively updated in the 1990s, requires funeral providers to give families a General Price List. It says nothing about the credit terms a funeral home may offer at the same table. The Rule covers the price of the casket. It does not cover the cost of borrowing to buy it.
The CFPB has jurisdiction over consumer lending and could apply the Truth in Lending Act to funeral BNPL products. For thirteen months, it chose not to. The agency's May 2025 announcement did not distinguish between BNPL used to buy a television and BNPL used to bury a parent.
State funeral boards license funeral directors and cemeteries. They do not regulate consumer lending. A family unhappy with the financing terms on a funeral has no obvious place to file a complaint that reaches someone with authority over the loan itself.
The gap persists because every party with the power to close it faces a cost and sees little benefit. The CFPB would have to reverse a policy decision its current leadership made publicly. Expanding the Funeral Rule would drag the FTC back into a fight with an industry that has resisted disclosure requirements for decades. State funeral boards license directors and cemeteries, not lenders, and a financing product falls outside their expertise. Meanwhile, the financing tool generates revenue for the funeral chain, volume for the fintech, and transactions that, on paper, close without default.
Lilypay's testimonials tell the other side of the ledger. A customer identified as R. Harris wrote that without the company, she had "no idea how I would have been able to give my late husband the dignified end of life he wanted." Another, T. Colter, described an unplanned funeral and a flat fee that was "reasonable." The demand is real. So is the fact that the demand exists because families are arriving at funeral homes without the money to pay, and without cheaper alternatives.
What this signals for the industry
The Foundation Partners deal is the first time a funeral chain of this scale has publicly embedded a dedicated BNPL lender into its arrangement process. It is unlikely to be the last. If the model lowers card processing costs and removes repayment risk while letting families finance more expensive services, the economics push every consolidator toward the same move.
The question is what families are told. A "0% interest" claim next to an 8 percent fee is the kind of framing the federal lending disclosure regime was built to prevent. A "soft pull, no impact on score" claim next to an installment agreement that permits credit bureau reporting of missed payments is the kind of gap families cannot be expected to navigate while planning a funeral. That regime, for BNPL, is currently unenforced. The FTC Funeral Rule does not reach it. State boards cannot.
Obitley has contacted Foundation Partners Group and Lilypay for comment on the fee structure, the credit reporting terms, and how the financing is presented to families at the arrangement table. Their responses will be published in full if received. Until then, Lilypay's published terms are the only public disclosure of the cost. For the 125,000 families who pass through Foundation Partners locations each year, those terms are now part of the conversation about how to say goodbye.
What This Means for You
*Sources: Foundation Partners Group and Lilypay partnership announcement, Connecting Directors, June 30, 2026; lilypay.co "How It Works" page, homepage, and customer testimonials, accessed July 1, 2026; Lilypay Installment Agreement, Sections 4 and 9, lilypay.co/installment-agreement, accessed July 1, 2026; CFPB Announcement Regarding Enforcement Actions Related to Buy Now, Pay Later Loans, May 6, 2025; CFPB BNPL data page (consumerfinance.gov/data-research/consumer-credit-trends/buy-now-pay-later/), now returns 404 as of July 1, 2026; Truth in Lending (Regulation Z), Use of Digital User Accounts to Access Buy Now, Pay Later Loans, 89 Fed. Reg. 47,068 (May 31, 2024); FTC Funeral Rule, 16 CFR Part 453.*
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