Special purpose credit programs

by Keith Schostag, NAFCU Compliance Blog

On Tuesday, February 22, 2022, NCUA issued Letter to Credit Unions, 22-CU-03 regarding special purpose credit programs. The letter informed credit unions of the release of an interagency statement on special purpose programs. The purpose of the letter and statement was to remind credit unions of their ability to offer special purpose programs that meet the needs of specified classes under the Equal Credit Opportunity Act (ECOA) and Regulation B. So, what are special purpose programs?

The ECOA and Regulation B, section 1002.8 permit creditor to provide “special purpose credit” to specific applicant types (such as the elderly) under the following programs:

  1. Credit assistance programs for an economically disadvantaged class that were expressly authorized by state or federal law;
  2. Credit assistance programs offered by a nonprofit (such as a credit union) for the benefit of its members or an economically disadvantaged class; and

 

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