News & Analysis as of

Special Purpose Credit Programs

Orrick, Herrington & Sutcliffe LLP

Court declines to halt Washington’s racial equity homeownership program

On February 9, the U.S. District Court for the Western District of Washington denied a motion for preliminary injunction in a case challenging Washington’s Covenant Homeownership Program, a special purpose credit program...more

Orrick, Herrington & Sutcliffe LLP

Senators pen letter urging CFPB to rescind its ECOA disparate impact rule

On February 3, several U.S. senators sent a letter to CFPB Acting Director Russell Vought urging the Bureau to rescind its proposed rule that would end the ECOA’s disparate impact test, which would prevent the CFPB from...more

Mayer Brown

Implications of the CFPB's Proposed Rule under the Equal Credit Opportunity Act

Mayer Brown on

Summary: In this episode of Financial Services Focus, Kris Kully and EY Managing Director of Financial Services Brian Clark discuss the Consumer Financial Protection Bureau's proposed rule under the Equal Credit Opportunity...more

Hudson Cook, LLP

CFPB Proposes Changes to Regulation B

Hudson Cook, LLP on

On November 13, the Consumer Financial Protection Bureau published a Notice of Proposed Rulemaking proposing various revisions to Regulation B. ...more

Dorsey & Whitney LLP

Responding to the CFPB’s Proposal to Eliminate Disparate Impact and Related Fair Lending Protections of Regulation B

Dorsey & Whitney LLP on

On November 13, 2025, the CFPB published in the Federal Register a significant proposed rule (the “Proposal”) that would radically diminish the protections against discriminatory lending practices afforded to protected...more

Hinshaw & Culbertson - Consumer Crossroads

The CFPB’s Proposed Disparate Impact Amendments to Regulation B

Earlier this year, President Trump issued Executive Order 14281 (the “Executive Order”) directing a review of existing federal regulations and guidance documents that impose disparate impact liability (sometimes referred to...more

Sheppard

CFPB Proposed Rule Dramatically Revises ECOA

Sheppard on

On November 13, the CFPB issued a sweeping proposed rule to overhaul Regulation B, arguably the most far-reaching ECOA rewrite in the agency’s history. The proposal would eliminate disparate-impact liability under ECOA,...more

Skadden, Arps, Slate, Meagher & Flom LLP

Key Takeaways From Fair Lending 2025: Navigating Turbulent Waters

On November 3, 2025, Skadden and Troutman co-hosted a conference in Washington, D.C. titled “Fair Lending 2025: Navigating Turbulent Waters.” Leading the conference were Anand Raman, head of Skadden’s Consumer Financial...more

Ballard Spahr LLP

CFPB wants to eliminate disparate-impact claims under ECOA

Ballard Spahr LLP on

The CFPB has issued a proposed rule that would make substantial changes to Regulation B under the Equal Credit Opportunity Act (ECOA). In one of the most significant changes, the bureau has preliminary determined that...more

Mayer Brown

CFPB Proposes Narrowing ECOA Regulations

Mayer Brown on

The Consumer Financial Protection Bureau (“CFPB”) has issued its proposed rule scaling back the interpretation of and regulations under the Equal Credit Opportunity Act (“ECOA”). While the agency placed the proposal on its...more

Bradley Arant Boult Cummings LLP

Regulation B Revisited: CFPB Proposes Amendments Addressing Disparate Impact, Discouragement, and Special Purpose Credit Programs

On November 13, 2025, the Consumer Financial Protection Bureau (CFPB) released a Notice of Proposed Rulemaking (NPRM) amending Regulation B – the regulation implementing the Equal Credit Opportunity Act (ECOA)....more

Orrick, Herrington & Sutcliffe LLP

CFPB proposes changes to Regulation B on disparate impact and other provisions

On November 13, the CFPB published a proposed rule in the Federal Register to amend Regulation B, which implements the ECOA. ...more

Troutman Pepper Locke

CFPB’s Proposed Reg B Overhaul: Ending ECOA Disparate Impact, Narrowing Discouragement, and Reshaping SPCPs

Troutman Pepper Locke on

The Consumer Financial Protection Bureau (CFPB or Bureau) has proposed an unprecedented, far‑reaching rewrite of Regulation B (Reg B) under the Equal Credit Opportunity Act (ECOA). If finalized, the proposed rule would...more

Sheppard

FHFA Rescinds UDAP Oversight Bulletin and SPCP-Based Renter Protections

Sheppard on

The Federal Housing Finance Agency (FHFA) has taken two significant deregulatory steps affecting its oversight of the government-sponsored enterprises, Fannie Mae and Freddie Mac (GSEs). The agency rescinded a 2024 advisory...more

Alston & Bird

DEI in Lending: Are Special Purpose Credit Programs About to DIE?

Alston & Bird on

For the last several years, federal agencies, including the Consumer Financial Protection Bureau (“CFPB”), have been strongly encouraging financial institutions to implement and offer targeted credit assistance to...more

Davis Wright Tremaine LLP

[Webinar] Hot Topics in Fair Servicing - April 13th, 11:00 am - 12:00 pm PT

The national and administrative focus on advancing racial equity and support for underserved communities keeps fair servicing in the foreground as a top priority for mortgage servicers. In this webinar, you’ll hear from a...more

Miller Nash LLP

Federal Regulators Continue to Encourage Special Purpose Credit Programs

Miller Nash LLP on

In a recent interagency statement, the federal banking regulators highlighted the availability of Special Purpose Credit Programs (SPCPs) as a tool for financial institutions to expand access to credit for underserved...more

Hudson Cook, LLP

CFPB Bites of the Month - March Top 10

Hudson Cook, LLP on

We thank you for reading our Top 10 and listening to our CFPB Bites of the Month webinars over the past two years. We are pleased to continue the series in 2022. In this month's article, we share some of our top "bites" for...more

Ballard Spahr LLP

CFPB, federal banking agencies, and other federal agencies issue Interagency Statement on Special Purpose Credit Programs Under...

Ballard Spahr LLP on

Yesterday, eight federal agencies joined together to issue an “Interagency Statement on Special Purpose Credit Programs Under the Equal Credit Opportunity Act and Regulation B” (Interagency Statement). The agencies consist...more

Perkins Coie

Fintech Week in Review - June 2021 #2

Perkins Coie on

A buy-now pay-later company faces a potential class action alleging it hid the risk of overdraft and NSF fees from its users. Leaders of the CFPB’s Fair Lending Office published an article encouraging the use of special...more

Perkins Coie

Fintech Week in Review - January 2021

Perkins Coie on

FDIC Creates New Exceptions for Fintech Companies with Its Final Brokered Deposit Rule - On December 15, 2020, the Federal Deposit Insurance Corporation (FDIC) finalized its updated brokered deposit rule, providing...more

Ballard Spahr LLP

CFPB Issues Advisory Opinion Addressing Regulatory Uncertainty Regarding Special Purpose Credit Programs

Ballard Spahr LLP on

On December 21, 2020, the CFPB issued an advisory opinion that addresses regulatory uncertainty related to certain aspects of special purpose credit programs (“SPCPs”) designed and implemented by for-profit organizations. The...more

Skadden, Arps, Slate, Meagher & Flom LLP

Special Purpose Credit Programs — Taking a Second Look at a Familiar Tool

Increasingly, lenders are interested in pursuing proactive efforts to increase lending opportunities for members of African-American, Hispanic and other communities that may have traditionally been underserved. These...more

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