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#2283057 - 04/05/23 02:53 PM FR 86 1-15-21 Advisory Opinion for SPCP
Auditgal Offline
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Joined: Dec 2014
Posts: 203
I am looking at the Advisory Opinion from CFPB to go with Reg B about Special Purpose Credit Programs. When it is discussing "for-profit organizations" is it referring to banks and that they must include a written plan that establishes and administers a SPCP under Reg B? I just stumbled upon this and so I am trying to determine applicability and is it something that banks should be doing and I'm behind?

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#2283060 - 04/05/23 03:27 PM Re: FR 86 1-15-21 Advisory Opinion for SPCP Auditgal
rlcarey Online
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rlcarey
Joined: Jul 2001
Posts: 85,059
Galveston, TX
If you have identified a need and have the time, energy, resources and competent legal assistance in developing such a program under the guidance - go for it. There are probably only a handful of such programs.
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The opinions expressed here should not be construed to be those of my employer: PPDocs.com

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#2283065 - 04/05/23 04:14 PM Re: FR 86 1-15-21 Advisory Opinion for SPCP rlcarey
Auditgal Offline
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Joined: Dec 2014
Posts: 203
I just wanted to determine if "for profit organization" meant banks and if "must" meant requirement for all, that is all I wanted to check on. I'm assuming that "must" does not mean "regulatory required" then.

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#2283066 - 04/05/23 04:16 PM Re: FR 86 1-15-21 Advisory Opinion for SPCP Auditgal
rlcarey Online
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rlcarey
Joined: Jul 2001
Posts: 85,059
Galveston, TX
Yes - a bank is a "for profit organization" and the "must" relates to "if" you have a program.
_________________________
The opinions expressed here should not be construed to be those of my employer: PPDocs.com

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