

Greater transparency in buy now, pay later activity is key to helping consumers build their credit histories and supporting responsible lending.
Experian North AmericaScott Brown, Group President, Financial Services

Affirm plans to report all pay-over-time loan products issued from April 1, 2025, and beyond, including Pay-in-4. The move will help drive greater transparency into the buy now, pay later market while helping consumers build their credit histories over time.

We believe that financial literacy leads to empowerment. That is why Experian supports initiatives and partners with community organizations to deliver financial education. We also develop products and services that give more control to consumers over their credit profile and financial health. As part of advancing our mission of Financial Power to All®, we are proud to announce we are helping more than 5,000 Hispanic individuals nationwide by relieving $10 million dollars of consumer debt. To provide families with this boost, we joined forces with ForgiveCo, a Public Benefit Corporation (PBC), to administer the acquisition and cancellation of qualifying consumer debt for the selected recipients. Beneficiaries will also receive a one-year premium Experian membership for free that offers access to their Experian credit report in English and Spanish[i], FICO® Score[ii], bilingual educational content, and other financial resources. We hope this effort helps raise awareness of the importance of financial literacy for everyone, and that Experian has resources to help individuals reach their financial dreams. To amplify the message, we collaborated with multi-platinum, award-winning singer and songwriter Prince Royce and you can see his video here. In fact, we have been making a concerted effort the last several years to evolve our educational resources and products to better support all underserved communities. Some of our other activities include the creation of the B.A.L.L. for Life initiative that connects African American and Hispanic youth with financial education, supporting scholarships for Asian Americans through the Ascend organization, providing custom resources for Out & Equal and Born This Way Foundation for the LGBTQ+ community, supporting the NextGen Innovation Lab for Disability:IN, and sponsoring credit counseling for the military community with Operation HOPE. For resources in Spanish, Experian offers a credit e-book and consumers can access a full suite of articles at the Ask Experian blog here. [i] Only Experian credit reports are available in Spanish. All other services associated with an Experian membership are available in English only. English fluency is required for full access to Experian’s products. [ii] Credit score calculated based on FICO® Score 8 model. Your lender or insurer may use a different FICO® Score than FICO® Score 8, or another type of credit score altogether. Learn more.

People rely on credit cards, personal loans, mortgages and auto loans, among other financial products to buy homes, fund college educations, weather temporary income disruptions and finance billions of daily transactions for goods and services. Credit is the cornerstone of the pursuit of our financial ambitions. That’s why the credit reporting industry is deeply committed to broadening access to fair and affordable financial resources for all consumers, particularly for individuals and households from underserved communities. The commitment is underscored by the continual effort to evolve the credit reporting system and incorporate new data sets to provide lenders a more comprehensive view of consumers’ ability and capacity to repay outstanding debt. Although progress has been made to extend credit to more prospective borrowers across the risk spectrum, if we want to continue to broaden the scope, we need to encourage the consistent reporting of additional predictive data sources to help lenders assess consumers’ creditworthiness. A proven track record but there’s more work to do Over the past century, the credit reporting industry transitioned from an opaque system founded on relationships to one rooted in data. Lenders lean on past payment history on similar loans (i.e., auto loans, mortgages, credit cards, etc.) as a reliable predictor of a borrower’s future loan payment performance—it’s a way for them to mitigate risk and say “yes” to more borrowers. And it works. The comprehensive reporting of past loan performance, coupled with increasingly sophisticated statistical prediction models, as well as the adoption of risk-based pricing, accelerated the extension of credit to more consumers. Yet, according to research from Experian and Oliver Wyman, millions of Americans lack access to mainstream credit because they are credit invisible, unscorable or have a subprime credit score. It’s particularly challenging for younger individuals, newly arrived immigrants and historically underserved communities, such as racial and ethnic minorities. At times it can be a catch-22; in order to get credit, you have to have credit. More predictive data is key At Experian, we’ve long understood that expanding the universe of creditworthy borrowers requires more data. In addition to some of the more conventional tradelines, such as mortgages, auto loans and credit cards, we have to explore expanded data sources that are predictive of a prospective borrower’s credit risk. For instance, more consumers are using buy now, pay later (BNPL) products, and nearly every consumer makes recurring monthly payments for rent, utilities, cell phones and even video streaming services, yet oftentimes, these data points are not consistently reported to the credit reporting agencies nor considered during lending decisions. Collectively, the industry and regulators, need to do more to encourage the consistent reporting and inclusion of expanded data onto consumers’ credit reports. In fact, based on our research, we’ve found that some of the aforementioned expanded data sources can empower lenders to assess the credit risk of a significantly larger pool of consumers. These expanded data sources have been shown to be highly accurate predictors of future loan payment behavior. And, when expanded data is combined with advanced analytics, up to 96% of the population can be scored, including an estimated 65% of credit invisibles.1 Broadening access to fair and affordable credit for more consumers means leaning into combining conventional tradelines with expanded Fair Credit Report Act-regulated data sources. The more information lenders have available to them about prospective borrowers’ past payment performance the more empowered they are to minimize risk and more confidently extend credit. Pushing for more data is the best path forward.

In an era where financial transactions occur at the click of a button, the significance of accurately verifying and authenticating consumers’ identities cannot be overstated. From online purchases to mobile banking, ensuring secure and reliable digital connections and safeguarding consumers’ information are table stakes for any business operating in the digital ecosystem. Unfortunately, some advocacy groups are calling for stricter regulatory guidelines that may impede business’ ability to effectively and efficiently protect a consumer’s financial information and identity. We’re, of course, referring to the push to classify credit header data— identifying information, such as name, current and former addresses, phone number and Social Security number, found at the top of credit reports—as a consumer report under the Fair Credit Reporting Act (FCRA). Subjecting credit header information to the FCRA will unnecessarily limit its permitted use, and effectively make it more difficult—and potentially impossible—for banks and other businesses to use the information to authenticate and verify consumers’ identities. It’s an unintended consequence that will surely compromise the security of our digital identities. Foundational to fraud prevention Credit header data plays a pivotal role in helping businesses detect suspicious activity and stay ahead of increasingly sophisticated fraud schemes. With credit header information, banks and other financial institutions cross-reference loan applications against transactions from hundreds of thousands of contributors to spot anomalies and thwart fraudsters before they inflict harm. In fact, many of the industry’s most advanced fraud prevention tools and signals rely on credit header data to verify the legitimacy of any given transaction. Keep in mind, the transactions we’re referring to are transactions of consequence. For instance, opening a new bank account, applying for a loan or transferring money. This level of activity carries inherent risk, and without proper vigilance, could result in significant financial or reputational harm to consumers and businesses. But it’s not only lenders that leverage credit header data, the use cases for credit header data are broad. Government agencies and businesses in the public sector, law enforcement, and some pharmacies use the information to issue one-time passcodes for identification purposes, find missing persons, or verify consumers’ identities prior to prescriptions being filled. Credit header data is already regulated Some of the concern surrounding credit header data centers on consumer privacy, and rightfully so. Protecting consumers’ privacy should be central to the use of sensitive information; however, credit header data is already regulated by the Gramm-Leach-Bliley Act. In fact, for more than 25 years, the Gramm-Leach-Bliley Act specifically provides that the permissible use of credit header data includes fraud prevention, while also mandating consumer privacy and data protection. Subjecting credit header data to additional FCRA regulation, which does not clearly allow for fraud prevention, could make it impractical or impossible for many businesses to use it for that purpose. Not only is additional regulation unnecessary, but it potentially creates a contradictory web of regulations that increases the compliance burden and confusion for many businesses. This ultimately thwarts the purpose of GLBA by delaying fraud prevention efforts and potentially raising costs for consumers. Credit header data is far more than information included at the top of consumers’ credit reports, it is a linchpin that powers many of the most advanced fraud prevention and identify verification tools in the market. Before any further regulation is considered, we have to acknowledge the role that credit header data plays in keeping consumers’ information safe and how any changes may impact the safety and soundness of our digital economy.



