- SPCP Basics
- Why SPCPs are needed
- FAQs: Legal Issues
- Market examples of SPCPs
- Building your SPCP
- Data & Design FAQs
- Data Analysis Examples
- Compliance and Monitoring
- SPCP Toolkit Contributors
Regulatory Guidance on SPCPs
The CFPB issued an Advisory Opinion that provides detailed agency guidance regarding the content that a for-profit organization should include in a SPCP written plan.
This blog on CFPB’s website provide a host of information, resources, and contacts that lenders who are building or deploying SPCPs will find helpful and useful.
HUD issued guidance that confirms that SPCPs that conform with ECOA and Reg B generally do not violate the Fair Housing Act (“FHA”).
The OCC, Board of Governors of the Federal Reserve System, FDIC, NCUA, CFPB, HUD, the U.S. DOJ, and FHFA issued a joint statement that “encourage[s] creditors to explore opportunities to develop special purpose credit programs consistent with ECOA and Regulation B requirements as well as applicable safe and sound lending principles.”
HUD’s Office of Fair Housing and Equal Opportunity issued an accompanying statement “encourag[ing] lenders to seriously consider establishing [SPCPs] that are consistent with the antidiscrimination and affirmative provisions of the [ECOA], Regulation B, and the [FHA].”