The Washington Report

September 1, 2025

In This Issue:

FHA Programs (Federal Housing Administration)

  • NAR Submits Comments on FHA Buy Now, Pay Later Request for Information
  • Housing Issues Update

  • HUD Withdraws Translated Materials
  • FHA Programs (Federal Housing Administration)

    NAR Submits Comments on FHA Buy Now, Pay Later Request for Information

    NAR submitted comments 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.

    Elayne Weiss, [email protected], 202-383-1084

    Housing Issues Update

    HUD Withdraws Translated Materials

    HUD Withdraws Translated Materials

    Following an Executive Order designating English as the official language of the United States, the Department of Housing and Urban Development (HUD) will transition all operations and programs to English-only communication, effective immediately. HUD will no longer provide non-English translation services, and all correspondence, publications, and digital content will be produced exclusively in English. Printed or digital materials referencing translation services—or presented in languages other than English—will be removed from HUD offices and HUD-funded facilities and replaced with English-only versions.

    Language assistance will only be provided where legally required, including for individuals with hearing, vision, or related disabilities. As part of the immediate rollout, HUD has withdrawn all translated documents from circulation and removed them from its website. This withdrawal affects resources previously used by REALTORS® and their clients to navigate federal housing programs.

    The withdrawn materials include multilingual guidance and forms explaining FHA loan requirements, disaster recovery assistance for families affected by natural disasters, Housing Choice Voucher program information, and healthy homes initiatives. These resources helped REALTORS® serve clients with limited English proficiency (LEP) to understand complex program requirements and application processes.

    NAR’s Advocacy Team met with HUD leadership on Monday, August 25 to understand the scope of these changes and to share their potential impact on members and clients. HUD welcomed NAR’s input on the necessity of translated documents to the homebuying process. NAR also discussed the prospect of hosting an archive of translated materials on its website for use by members. NAR is committed to helping members serve buyers of all backgrounds and continues to engage with HUD and policymakers on these issues.

    Alexia Smokler, [email protected], 202-383-1210
    Caitlin Vannoy, [email protected], 202-383-1127
    Elayne Weiss, [email protected], 202-383-1084

    Valuation Issues Update

    FHA Announces Transition to New Appraisal Reporting in 2026

    On August 27, the FHA announced (in FHA INFO 2025-42) their intention to transition appraisal reporting to the new Uniform Appraisal Dataset (UAD) 3.6 beginning in Spring 2026 for early adopters. They will announce a timeline of the transition plan, updated policies, and technical specifications later this year, with a transition period similar to Fannie Mae and Freddie Mac (the GSEs) to allow for both legacy and UAD 3.6 appraisal reports for a period of time. 

    Both GSEs will begin their early adoption period for the new appraisal reports on Sept. 8, 2025, with broad production beginning in January of 2026, and a mandate to use the new appraisal reporting in November of 2026.

    The new appraisal report is designed to also accommodate USDA and VA loans, although those entities have not yet announced adoption timelines. 

    Keisha Wilkinson, [email protected], 202-383-1108