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
Problems with lack of affordability and access to housing are longstanding in the U.S. The CFPB has indicated that “minority households… continue to lack fair and equitable access to credit,” including mortgage lending. These...more
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
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
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
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
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