By: Kyle Tucker, Financial Institution Specialist
An interagency statement has been issued to remind creditors of the ability under the Equal Credit Opportunity Act (ECOA) and Regulation B to establish special purpose credit programs to meet the credit needs of specified classes of persons. This applies to all FDIC-supervised financial institutions.
On December 21, 2020, an Advisory Opinion was issued by the CFPB to clarify what type of research and data that may be appropriate to inform a for-profit organization’s determination to establish a special purpose credit program to benefit a specified class of persons.
The U.S. Department of Housing and Urban Development released guidance on December 7, 2021 concluding that special purpose credit programs instituted in conformity with the ECOA and Regulation B generally do not violate the FHA. The agencies do not determine whether a program qualifies for special purpose credit status, but creditors may consult their regulatory agencies for questions about any aspect of ECOA and Regulation B’s special purpose credit provisions.
For more information on this topic, please follow the link below:
https://www.fdic.gov/news/financial-institution-letters/2022/fil22008a.pdf
An interagency statement has been issued to remind creditors of the ability under the Equal Credit Opportunity Act (ECOA) and Regulation B to establish special purpose credit programs to meet the credit needs of specified classes of persons. This applies to all FDIC-supervised financial institutions.
On December 21, 2020, an Advisory Opinion was issued by the CFPB to clarify what type of research and data that may be appropriate to inform a for-profit organization’s determination to establish a special purpose credit program to benefit a specified class of persons.
The U.S. Department of Housing and Urban Development released guidance on December 7, 2021 concluding that special purpose credit programs instituted in conformity with the ECOA and Regulation B generally do not violate the FHA. The agencies do not determine whether a program qualifies for special purpose credit status, but creditors may consult their regulatory agencies for questions about any aspect of ECOA and Regulation B’s special purpose credit provisions.
For more information on this topic, please follow the link below:
https://www.fdic.gov/news/financial-institution-letters/2022/fil22008a.pdf
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