On December 21, 2020, the Consumer Financial Protection Bureau published an Advisory Opinion (AO) on Special Purpose Credit Programs established per the requirements of the Equal Credit Opportunity Act and Regulation B. It is designed to address regulatory uncertainty in special purpose credit programs designed and implemented by for-profit organizations to meet special social needs. Specifically, this AO clarifies:
- The content that a for-profit organization must include in a written plan that establishes and administers a special purpose credit program under Regulation B; and
- The type of research and data that may be appropriate to inform a for-profit organization’s determination that a special purpose credit program is needed to benefit a certain class of persons.
This Advisory Opinion is effective upon publication in the Federal Register.