ARTICLE · 22 JUNE 2026

CFPB Rescinds 2020 Advisory Opinion On Special Purpose Credit Programs

Goodwin Procter LLP

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On June 17, 2026, the Consumer Financial Protection Bureau (CFPB) rescinded its December 2020 advisory opinion regarding Special Purpose Credit Programs (SPCPs) under the Equal Credit Opportunity Act (ECOA)...

United StatesConsumer Protection

On June 17, 2026, the Consumer Financial Protection Bureau (CFPB) rescinded its December 2020 advisory opinion regarding Special Purpose Credit Programs (SPCPs) under the Equal Credit Opportunity Act (ECOA) and Regulation B. The Bureau stated that the advisory opinion no longer reflects current law and guidance following amendments to Regulation B adopted in April 2026.

Background on the ECOA and SPCPs

The ECOA generally prohibits creditors from discriminating in credit transactions on the basis of protected characteristics such as race, color, religion, national origin, sex, marital status, age, receipt of public assistance, or the exercise of rights under consumer protection laws. At the same time, the ECOA permits certain SPCPs established by for-profit organizations to address specific social needs, provided those programs comply with standards established by the CFPB.

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