NAR submitted commentspdf encouraging the Federal Housing Administration to prioritize comprehensive data collection and analysis before implementing policy changes regarding Buy Now, Pay Later (BNPL) lending and mortgage underwriting. The comments were submitted in response to FHA's Request for Information (RFI).
NAR emphasized that significant data gaps exist regarding how consumers use BNPL products and their actual impact on borrower performance. The organization noted that BNPL usage patterns vary considerably – from one-time purchases after major life events to routine expenses – and that without comprehensive understanding of these patterns, policy changes could have unintended consequences.
NAR recommended that FHA ensure any modifications to underwriting standards are evidence-based and avoid creating unnecessary barriers for qualified borrowers seeking homeownership opportunities.
FHA published the RFI on June 27, 2025, seeking input on how BNPL products affect mortgage lending. According to the Consumer Financial Protection Bureau, 21% of consumers with credit records used BNPL products in 2022, but most BNPL obligations aren't reported to credit bureaus, creating challenges for lenders assessing borrower risk. FICO announced in June 2025 that it will launch new credit scores incorporating BNPL data, expected to be available in fall 2025.