In May 2024, new guidelines were proposed by the Consumer Financial Protection Bureau (CFPB) that would require Buy Now, Pay Later (BNPL) providers to share consumer payment information with credit reporting agencies (CRAs). Although data reporting about BNPL activity isn’t mandated through the Fair Credit Reporting Act, issuers have begun reporting payment information to CRAs.
While this proposed guidance from the CFPB focuses on BNPL activity, it signals a broader shift in how the credit landscape is evolving—particularly for lenders relying on a holistic view of consumer financial behavior. As of June 2025, the CFPB has stated it isn’t enforcing its guidance on BNPL activity and it isn’t issuing new guidance.The direction is clear: credit evaluations are moving toward a more complete picture of how people manage their everyday spending and credit obligations. This includes recognizing consistent patterns in recurring, nontraditional payments—such as BNPL installments, rent, and utilities—and ensuring these behaviors can be factored into credit-related decisioning models to afford consumers appropriate recognition of their financial handling, as well as giving credit granters a comprehensive view.
BNPL reform mirrors the mortgage market’s credit overhaul
BNPL activity is increasingly being evaluated using the same reporting standards as other forms of consumer credit. This shift reflects a broader transformation in how lenders assess financial behavior.
Modern credit evaluations place greater emphasis on trended data that shows patterns in how consumers have used and managed credit over time. They also incorporate alternative payment history—such as rental and utility payments—creating a more complete view of a consumer’s financial habits. These approaches have demonstrated stronger predictive performance, particularly for individuals with limited traditional credit history.
Overall, the direction of credit evaluation is moving toward broader data inclusion, both historical and real-time, for a more holistic, consumer‑centric assessment.
Although the CFPB has delayed implementation of these models, the direction is clear. Credit scoring is moving toward broader data inclusion and more accurate, consumer-centric evaluation.
Why mortgage lenders should care about BNPL rules
Modern expectations for credit evaluations are shifting toward a more complete, past-and-present view of consumers’ everyday financial behaviors. This applies across lending decisions, including those made in the mortgage ecosystem.
When consistent patterns—such as on‑time rent payments, responsible installment management, and steady cash‑flow habits—are visible, they can help create a clearer picture of an individual’s financial reliability. These signals are becoming increasingly important, especially as more future homebuyers have limited traditional credit histories.
Consider the impact of incorporating rental payment data:
- More than 83% of consumers who had rental payments included in their credit files saw an improvement in their scores
- 15.1% of those individuals were previously unscoreable and gained a score
- On average, consumers saw a 3.9% score increase after rental data was added
As more people use BNPL services and other nontraditional financial tools, it becomes increasingly important for mortgage lenders to evolve their evaluation inputs to reflect how consumers manage their financial lives today.
How mortgage lenders can prepare
With mounting regulatory and industry pressure, lenders need to move from passive observation to proactive implementation. Here’s how to begin:
1. Adopt the Experian Score Choice Bundle
This solution provides both FICO 2 and VantageScore 4.0 on every mortgage transaction at no additional cost. It allows lenders to:
- Compare and test new models without operational disruption
- Maintain compliance with GSE guidelines
- Serve more borrowers by evaluating modern credit behaviors
2. Score cash flow with decision-grade rigor
Plaid captures the data; Experian turns it into decision‑ready insight. Experian’s Cashflow Attributes and Cashflow Score provide:
- Decision-grade scoring built on permissioned transaction data
- Clear reason codes for explainability
- Stronger predictive lift backed by portfolio testing
With a growing majority of high-volume mortgage originators now implementing digital income and employment verification tools like Experian Verify, the industry is rapidly transitioning toward automated, real-time lending. As Experian positions it: “Plaid collects the signal. Experian makes it decision-ready.”
3. Align with market and regulatory trends
The FHFA’s shift to VantageScore 4.0 and FICO 10T, along with the emergence of cash flow payloads, signals that credit reporting is entering a new phase. Lenders proactively modernizing their credit strategies will be positioned to:
- Expand access to credit for millions of underserved but creditworthy consumers
- Reduce risk through more complete borrower insights
- Stay ahead of compliance and investor expectations
With over 53% of high-volume mortgage originators already using Experian Verify, the industry is beginning to embrace this transformation. Broader adoption of inclusive scoring and permissioned data remains a critical next step.
Final thought
The CFPB’s action on BNPL, while not enforced at the moment, is not an isolated event—it is a preview of the future. The mortgage industry must prepare now for a world where rent, cash flow, and alternative financial behavior shape the foundation of credit scoring. Lenders who act early will not only meet regulatory expectations but will gain a strategic advantage in serving tomorrow’s homebuyers.
Experian is ready to support this shift with data, tools, and scoring models built for the next era of mortgage lending.
Start testing modern credit scoring strategies now—and let Experian show you the lift on your borrower population.
VP Product Management
Kevin Clements oversees Experian’s Mortgage Product alignment and development pertaining to the solution sets delivered in the mortgage Originations vertical. In this role, Clements helps drive Experian’s mission to deliver a more streamlined mortgage process with data and analytics through a relentless evaluation of a fast, frictionless, and secure borrowing experience for lenders and consumers.
