I'm not saying there isn't a reason for such a high rate, and obviously it's better than a 60-70% rate, if that really is the only other alternative.
But for anyone with any credit rating at all, I would imagine they would probably be better off getting a credit card and dealing with the issues alluded to. Yes, it may be easy to overspend if you're not careful, but if you are careful, the rates are likely to be much better (capped by law), and you get additional benefits to paying by CC.
That said, I haven't seen the business plan, so maybe there's some other reason beyond "I might overspend" as to why someone who could potentially qualify for a CC would get this.
Follow up question: how can you afford to offer more reasonable rates if the credit card companies can't?
The cost structure of banks is mainly about credit risk (defaults), fixed costs, origination and servicing costs, and funding costs. For startups the funding costs is the biggest problem because banks fund themselves at close to 0% out of deposits. We have to raise expensive debt. As we drive this cost down, we will have much better conditions for users and merchants
As we drive our costs lower, we will be able to offer dramatically more low interest rates and now we are testing 0% APR programs with some of our merchants
Not a criticism at all, because no doubt you are offering choices to people that currently don’t exist, but isn’t 40% APR still insane?
Sounds like you do some kind of quick, automated credit scoring. How does that work in Mexico and countries south? Do the big three scourges of the US reach into CA and SA?