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Abstract: 

In this article, the authors discuss the framework for special purpose credit programs authorized by the Equal Credit Opportunity Act. They provide an overview of existing court decisions and regulatory guidance interpreting the requirements applicable to for-profit institutions for establishing ECOA-compliant special purpose credit programs. Next, they identify potential legal risks and best practices for institutions that seek to implement special purpose credit programs to help meet special social needs while minimizing those risks.

Keywords: Equal Credit Opportunity Act (ECOA); Fair Housing Act (FHA); United States v. Am. Future Sys., Inc.; Equal Credit Opportunity (Regulation B); Special Purpose Credit Programs, 86 Fed. Reg. 3762, 3763; Compliance and Legal Risks

Affiliations:  1: Mitchell Sandler PLLC; 2: Mitchell Sandler PLLC; 3: Mitchell Sandler PLLC.