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ARTICLE · 24 JUNE 2026

CFPB Rescinds 2020 Special Purpose Credit Program Advisory Opinion

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The Consumer Financial Protection Bureau has rescinded its 2020 advisory opinion on Special Purpose Credit Programs under Regulation B, citing outdated interpretations and constitutional concerns. This action follows April 2026 amendments that fundamentally altered the regulatory framework governing how for-profit organizations can establish credit programs designed to meet special social needs.

United StatesConsumer Protection
A.J. Dhaliwal
A.J. Dhaliwal
Mehul Madia
Mehul Madia
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On June 17, the CFPB rescinded its December 2020 advisory opinion addressing Special Purpose Credit Programs (SPCPs) under Regulation B and the Equal Credit Opportunity Act (ECOA). The 2020 guidance had sought to clarify certain requirements applicable to for-profit organizations establishing SPCPs designed to meet special social needs.

According to the Bureau, the 2020 advisory opinion had become outdated and contained statements that conflicted with the amended regulation. The CFPB also stated that rescinding the opinion would help avoid confusion regarding the applicable requirements for such programs and address constitutional concerns identified by the Bureau.

Specifically, the CFPB stated that the 2020 advisory opinion:

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