Good question, maybe I spoke too quick. I think they might be since they extend credit and deal with connections to the banking system. But I'm NAL. At least they are going to require a real world identity when giving out credit card numbers, which is also true of traditional card companies.

Mostly I'm OK with them knowing my IRL identity, and proving that to them. But I'm not OK with sending a digital photo of my DL to some 3rd party identity broker who tends to leak those a lot.