What: On June 24, 2025, the Department of Housing and Urban Development (HUD) published a Request for Information (RFI) seeking comments to better understand the implications of Buy Now Pay Later (BNPL) lending on housing affordability and stability. Information gathered in response to this RFI will inform HUD’s efforts to ensure that FHA single family mortgage insurance policies effectively address the evolving financial landscape and support the needs of American households.
Why: This RFI solicits comments on how BNPL obligations may affect the ability of FHA lenders to accurately assess risk, the impact of BNPL lending on housing affordability and stability, and whether policy changes are needed to preserve sound mortgage underwriting standards. HUD welcomes all comments relevant to BNPL loans and their impact on housing affordability and stability, including but not limited to:
- Evaluation methods used by mortgage lenders and underwriters to identify BNPL obligations.
- Risk assessment and loan approval challenges faced by underwriters when considering borrowers with BNPL debt.
- Debt-to-income (DTI) calculations are used in mortgage eligibility, especially when obligations are not visible in credit reports.
- Recommended policy measures to ensure that BNPL obligations are appropriately considered in DTI calculations without imposing undue burdens on borrowers or lenders.
Action: HUD’s Request for Information is published in the Federal Register. Comments are due to HUD on or before August 25, 2025.
RFI
FR-6547-N-01 Request for Information Regarding Buy Now Pay Later Unsecured Debt
CONTACT:
Will Purcell
EMAIL:
TOPIC(S):
HUD
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