As previously reported, in February 2022, eight federal agencies issued an Interagency Statement encouraging the offering of special purpose credit programs (SPCPs) under the Equal Credit Opportunity Act (ECOA). The agencies were the CFPB, FDIC, OCC, Fed, NCUA, HUD, DOJ, and FHFA. Seven of the agencies have now rescinded the Interagency Statement.… Continue Reading
Interagency Statement
CFPB, federal banking agencies, and other federal agencies issue Interagency Statement on Special Purpose Credit Programs Under the Equal Credit Opportunity Act and Regulation B
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 of the CFPB, FDIC, OCC, Federal Reserve Board, NCUA, HUD, DOJ, and FHFA. The Interagency Statement indicates that it is intended “to remind creditors of the ability under the Equal Credit Opportunity Act (ECOA) and Regulation B to establish special purpose credit programs to meet the credit needs of specified classes of persons” and to “call[] attention to the special purpose credit options under ECOA and Regulation B.”… Continue Reading
Five federal regulators issue statement clarifying role of supervisory guidance; Ballard Spahr to discuss interagency statement in Oct. 10 webinar on CFPB’s Summer 2018 Supervisory Highlights
By Ballard CFS Group on
Posted in Federal Agencies, Regulatory and Enforcement
In what seems to be a response to the Government Accountability Office’s (“GAO”) determination that the Consumer Financial Protection Bureau’s indirect auto finance bulletin (the “Bulletin”) was a rule subject to the Congressional Review Act (“CRA”) and a rebuke to the Bureau’s prior approach of “rulemaking by enforcement,” the Board of Governors of the Federal Reserve System, Federal Deposit Insurance Corporation, National Credit Union Administration, Office of the Comptroller of the Currency and the Bureau (collectively, the “agencies”) this week issued an Interagency Statement Clarifying the Role of Supervisory Guidance (the “Interagency Statement”).… Continue Reading