BNPL Metro 2 Reporting Guide

TL;DR

Use Portfolio Type I (Installment) and Account Type 07 / 19 for Pay-in-4 and revolving BNPL.
Set terms_frequency = B (biweekly) for Pay-in-4; terms_duration = 004 for the 4-payment plan.
Always set business_industry_code on the portfolio when routing to Equifax's BNPL specialty file.
Never use status DA for obsolete records — omit the tradeline instead (FCRA 7-year rule).
DOFD is suppressed in Phase 1 because Pay-in-4 cycles are shorter than the 30-day bureau bucket.

Portfolio + Account Type cheat sheet

BNPL reporting splits into two flavours: Pay-in-4 (4 biweekly payments, no interest) and longer-term installment (3-24 months, may carry interest). Equifax's specialty BNPL file accepts both, with the BIC field routing the record to the BNPL exchange rather than the mainline FICO scoring file.

Product	Portfolio Type	Account Type	Terms Frequency
Pay-in-4	I	07	B (biweekly)
Pay-in-6 / Pay-in-8	I	07	B (biweekly)
3-24 month installment	I	07 / 19	M (monthly)
BNPL line of credit	R	19	M (monthly)

Status code playbook

BNPL statuses are a subset of the broader CRRG codes. Use status 11 (Current) for accounts paying as scheduled, even mid-cycle. Once a payment is late, jump to the appropriate delinquency bucket (62-85). Charge-off uses status 97 and triggers original_charge_off_amount as required.

11 — Current (use through the entire Pay-in-4 cycle if no missed payments)
61 — Account 30 days past due
62 — Account 60 days past due
78 — Account 60-89 days past due, paying as agreed (rare in BNPL)
97 — Charged off (requires original_charge_off_amount)
DA — DO NOT USE for obsolescence; omit the record instead

Required segments

BNPL files use the base segment plus J1 / J2 when there's a co-buyer (rare). K1 is required for accounts that were sold to a debt buyer. K3 is mortgage-only and must NOT appear on BNPL records.

Compliance landmines

The Senate Banking Committee (Warren / Blumenthal, May 2026) pushed bureaus on BNPL reporting consistency. Equifax (Feb 2025) allowed BNPL to report as installment or revolving — pick one per product line and stay consistent. The CFPB withdrew its 2024 rule classifying BNPL as a credit card, but FCRA still applies: any furnished record must be accurate, complete, and disputable.

Always furnish through a written data-furnisher agreement — Pay-in-4 lenders that 'just send a file' invite §623 exposure.
If a consumer disputes, the e-OSCAR ACDV must be responded to within 30 days.
Don't report Pay-in-4 to bureaus that flag BNPL as 'experimental' — check your contributor scope first.

Dispute pattern responses

Three patterns dominate BNPL disputes: 'I paid on time' (timing window mismatch), 'I never authorised this loan' (fraud / takeover), and 'This is reporting twice' (same loan reported via merchant + lender path).

Timing-window disputes: check your DOFD = last paid date + 30. If you reported DOFD on day 7 of missed payment, fix it.
Fraud disputes: report status 04 + Special Comment AT (account closed at consumer's request) only if you can prove fraud.
Duplicate disputes: deduplicate on (merchant + consumer + amount + date) at file-build time, not at the bureau.

Sample CSV column dictionary

Most BNPL exports look like this. The seeded mapping template auto-detects the common variants.

Your column	Metro 2 target
loan_id	consumer_account_number
amount_financed	highest_credit_or_original_loan_amount
current_balance	current_balance
first_name	first_name
last_name	surname
opened_at	date_opened
scheduled_payment	scheduled_payment_amount
actual_payment	actual_payment_amount

Test checklist

Before flipping the switch to live transmission:

Generate a sample file via /api/metro2-records/generate-file?environment=test and run it through the in-app validator.
Confirm business_industry_code appears in the header segment.
Confirm no record has status DA.
Confirm terms_frequency is consistent within a portfolio (don't mix B and M in one file).
Run a small batch through Equifax's BNPL test endpoint before going prod.

Try this preset