FHA Seeks Comment on Buy Now Pay Later Unsecured Debt

FHA has published a Request for Information seeking comment on how “Buy Now, Pay Later” (BNPL) lending impacts the ability of FHA-approved lenders to evaluate borrower risk and the stability of the housing market as a whole. 

BNPL obligations are typically not reported to credit bureaus and therefore could create “phantom debt” mortgagees are not able to fully assess to determine the borrower’s obligations and debt management behavior.

The deadline for comments is August 25, 2025, although FHA indicates that late comments will be considered to the extent practicable.