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ARTICLE · 31 AUGUST 2026

Federal Agencies Rescind 2022 Special Purpose Credit Program Guidance

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Seven federal agencies have rescinded their 2022 guidance on Special Purpose Credit Programs under the Equal Credit Opportunity Act, stating that creditors can no longer rely on prior interpretations that encouraged such programs. The agencies emphasized that SPCPs must now strictly comply with ECOA, Regulation B, and the Fair Housing Act, marking a significant shift in federal fair-lending policy. This action follows related withdrawals by HUD and the CFPB, signaling a broader federal retreat from guidance

United StatesFinance and Banking
A.J. Dhaliwal
A.J. Dhaliwal
Mehul Madia
Mehul Madia
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On August 25, seven federal agencies rescinded their 2022 interagency statement addressing Special Purpose Credit Programs (SPCPs) under the Equal Credit Opportunity Act (ECOA) and Regulation B. The FDIC, NCUA, OCC, CFPB, HUD, DOJ, and FHFA stated that creditors should no longer rely on the prior guidance and emphasized that SPCPs must comply with ECOA, Regulation B, and, where applicable, the Fair Housing Act (FHA).

The 2022 statement had encouraged creditors to establish SPCPs designed to meet the credit needs of specified classes of persons and provided assurances regarding the permissibility of those programs. According to the agencies, however, the statement relied in part on a provision of Regulation B that has since been amended and on HUD guidance concerning the FHA that is no longer in effect. The agencies stated that those prior interpretations cannot be reconciled with the statutory text of ECOA and the FHA.

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