Regulatory Guidance on SPCPs

CFPB Advisory Opinion

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.

CFPB SPCP Resource Blog

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 General Counsel Opinion

HUD issued guidance that confirms that SPCPs that conform with ECOA and Reg B generally do not violate the Fair Housing Act (“FHA”).

Interagency Statement on SPCPs

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 FHEO Statement

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].”