Independent Banker - June 2022 - 28

PORTFOLIO
" The more recent releases [on SPCPs] from
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regulatory agencies ... reemphasize that these
tools are available to lenders and how to create
a written plan and set up such a program. "
-MICHAEL MARSHALL, ICBA
applicable under section 501(c) of
the Internal Revenue Code of 1954
for the benefit of its members or
for the benefit of an economically
disadvantaged class of persons; or to
meet special social needs.
Special purpose credit program
standards update
An SPCP must meet certain criteria,
including:
ƒ A written plan. It must be
established and administered
pursuant to a written plan that
identifies the class of persons that
the program is designed to benefit
and sets forth the procedures and
standards for extending credit
under the program.
REGISTER TODAY!
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library of free on-demand
webinars, visit the Independent
Banker Webinar Center at
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ƒ A demonstrated need for the
program. It must be established
and administered to extend credit
to a class of persons who, under the
organization's customary standards
of creditworthiness, probably would
not receive such credit or would
receive it on less favorable terms
than are ordinarily available to
other applicants applying to the
organization for a similar type and
amount of credit.
ƒ Precludes discrimination on
a prohibited basis. It must be
established and administered so
as not to discriminate against an
applicant on any prohibited basis.
Regulators have heightened
their focus on SPCP due in part to
social trends, political influence and
initiatives of Consumer Financial
Protection Bureau (CFPB) director
Rohit Chopra for access to credit,
fair lending and discrimination.
In July 2020, the CFPB published
encouragement to both for-profit
and not-for-profit creditors of
the availability under ECOA and
Regulation B of SPCPs to meet
the credit needs of underserved
communities. In December 2020,
CFPB published an Advisory
Opinion to clarify what a for-profit
organization must include in a written
plan to establish and administer a
SPCP under Regulation B and the
type of research and data that may
be appropriate to support a for-profit
organization's determination that an
SPCP is needed to benefit a certain
class of persons.
Tailored terms and tools
In response to requests from lenders,
stakeholders and other federal
agencies, the U.S. Department of
Housing and Urban Development
(HUD) released guidance in December

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Independent Banker - June 2022

Table of Contents for the Digital Edition of Independent Banker - June 2022

Table of Contents
Independent Banker - June 2022 - Intro
Independent Banker - June 2022 - Cover1
Independent Banker - June 2022 - Cover2
Independent Banker - June 2022 - Table of Contents
Independent Banker - June 2022 - 2
Independent Banker - June 2022 - 3
Independent Banker - June 2022 - 4
Independent Banker - June 2022 - 5
Independent Banker - June 2022 - 6
Independent Banker - June 2022 - 7
Independent Banker - June 2022 - 8
Independent Banker - June 2022 - 9
Independent Banker - June 2022 - 10
Independent Banker - June 2022 - 11
Independent Banker - June 2022 - 12
Independent Banker - June 2022 - 13
Independent Banker - June 2022 - 14
Independent Banker - June 2022 - 15
Independent Banker - June 2022 - 16
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Independent Banker - June 2022 - 18
Independent Banker - June 2022 - 19
Independent Banker - June 2022 - 20
Independent Banker - June 2022 - 21
Independent Banker - June 2022 - 22
Independent Banker - June 2022 - 23
Independent Banker - June 2022 - 24
Independent Banker - June 2022 - 25
Independent Banker - June 2022 - 26
Independent Banker - June 2022 - 27
Independent Banker - June 2022 - 28
Independent Banker - June 2022 - 29
Independent Banker - June 2022 - 30
Independent Banker - June 2022 - 31
Independent Banker - June 2022 - 32
Independent Banker - June 2022 - 33
Independent Banker - June 2022 - 34
Independent Banker - June 2022 - 35
Independent Banker - June 2022 - 36
Independent Banker - June 2022 - 37
Independent Banker - June 2022 - 38
Independent Banker - June 2022 - 39
Independent Banker - June 2022 - 40
Independent Banker - June 2022 - 41
Independent Banker - June 2022 - 42
Independent Banker - June 2022 - 43
Independent Banker - June 2022 - 44
Independent Banker - June 2022 - 45
Independent Banker - June 2022 - 46
Independent Banker - June 2022 - 47
Independent Banker - June 2022 - 48
Independent Banker - June 2022 - 49
Independent Banker - June 2022 - 50
Independent Banker - June 2022 - 51
Independent Banker - June 2022 - 52
Independent Banker - June 2022 - 53
Independent Banker - June 2022 - 54
Independent Banker - June 2022 - 55
Independent Banker - June 2022 - 56
Independent Banker - June 2022 - 57
Independent Banker - June 2022 - 58
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Independent Banker - June 2022 - 60
Independent Banker - June 2022 - 61
Independent Banker - June 2022 - 62
Independent Banker - June 2022 - 63
Independent Banker - June 2022 - 64
Independent Banker - June 2022 - 65
Independent Banker - June 2022 - 66
Independent Banker - June 2022 - 67
Independent Banker - June 2022 - 68
Independent Banker - June 2022 - 69
Independent Banker - June 2022 - 70
Independent Banker - June 2022 - 71
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Independent Banker - June 2022 - 73
Independent Banker - June 2022 - 74
Independent Banker - June 2022 - 75
Independent Banker - June 2022 - 76
Independent Banker - June 2022 - Cover3
Independent Banker - June 2022 - Cover4
https://www.nxtbook.com/mspc/independentbanker/october2024
https://www.nxtbook.com/mspc/independentbanker/september2024
https://www.nxtbook.com/mspc/independentbanker/august2024
https://www.nxtbook.com/mspc/independentbanker/july2024
https://www.nxtbook.com/mspc/independentbanker/june2024
https://www.nxtbook.com/mspc/independentbanker/may2024
https://www.nxtbook.com/mspc/independentbanker/april2024
https://www.nxtbook.com/mspc/independentbanker/march2024
https://www.nxtbook.com/mspc/independentbanker/february2024
https://www.nxtbook.com/mspc/independentbanker/january2024
https://www.nxtbook.com/mspc/independentbanker/december2023
https://www.nxtbook.com/mspc/independentbanker/november2023
https://www.nxtbook.com/mspc/independentbanker/october2023
https://www.nxtbook.com/mspc/independentbanker/september2023
https://www.nxtbook.com/mspc/independentbanker/august2023
https://www.nxtbook.com/mspc/independentbanker/july2023
https://www.nxtbook.com/mspc/independentbanker/june2023
https://www.nxtbook.com/mspc/independentbanker/may2023
https://www.nxtbook.com/mspc/independentbanker/april2023
https://www.nxtbook.com/mspc/independentbanker/march2023
https://www.nxtbook.com/mspc/independentbanker/february2023
https://www.nxtbook.com/mspc/independentbanker/january2023
https://www.nxtbook.com/mspc/independentbanker/december2022
https://www.nxtbook.com/mspc/independentbanker/november2022
https://www.nxtbook.com/mspc/independentbanker/october2022
https://www.nxtbook.com/mspc/independentbanker/september2022
https://www.nxtbook.com/mspc/independentbanker/august2022
https://www.nxtbook.com/mspc/independentbanker/july2022
https://www.nxtbook.com/mspc/independentbanker/june2022
https://www.nxtbook.com/mspc/independentbanker/may2022
https://www.nxtbook.com/mspc/independentbanker/april2022
https://www.nxtbook.com/mspc/independentbanker/march2022
https://www.nxtbook.com/mspc/independentbanker/february2022
https://www.nxtbook.com/mspc/independentbanker/january2022
https://www.nxtbook.com/mspc/independentbanker/december2021
https://www.nxtbook.com/mspc/independentbanker/november2021
https://www.nxtbook.com/mspc/independentbanker/october2021
https://www.nxtbook.com/mspc/independentbanker/september2021
https://www.nxtbook.com/mspc/independentbanker/august2021
https://www.nxtbook.com/mspc/independentbanker/july2021
https://www.nxtbook.com/mspc/independentbanker/june2021
https://www.nxtbook.com/mspc/independentbanker/may2021
https://www.nxtbook.com/mspc/independentbanker/april2021
https://www.nxtbook.com/mspc/independentbanker/march2021
https://www.nxtbook.com/mspc/independentbanker/february2021
https://www.nxtbook.com/mspc/independentbanker/january2021
https://www.nxtbook.com/mspc/independentbanker/december2020
https://www.nxtbook.com/mspc/independentbanker/november2020
https://www.nxtbook.com/mspc/independentbanker/october2020
https://www.nxtbook.com/mspc/independentbanker/september2020
https://www.nxtbook.com/mspc/independentbanker/august2020
https://www.nxtbook.com/mspc/independentbanker/july2020
https://www.nxtbook.com/mspc/independentbanker/june2020
https://www.nxtbook.com/mspc/independentbanker/may2020
https://www.nxtbook.com/mspc/independentbanker/april2020
https://www.nxtbook.com/mspc/independentbanker/march2020
https://www.nxtbook.com/mspc/independentbanker/february2020
https://www.nxtbook.com/mspc/independentbanker/january2020
https://www.nxtbook.com/mspc/independentbanker/december2019
https://www.nxtbook.com/mspc/independentbanker/november2019
https://www.nxtbook.com/mspc/independentbanker/october2019
https://www.nxtbook.com/mspc/independentbanker/september2019
https://www.nxtbook.com/mspc/independentbanker/august2019
https://www.nxtbook.com/mspc/independentbanker/july2019
https://www.nxtbook.com/mspc/independentbanker/june2019
https://www.nxtbook.com/mspc/independentbanker/may2019
https://www.nxtbook.com/mspc/independentbanker/april2019
https://www.nxtbook.com/mspc/independentbanker/march2019
https://www.nxtbook.com/mspc/independentbanker/february2019
https://www.nxtbook.com/mspc/independentbanker/january2019
https://www.nxtbook.com/mspc/independentbanker/december2018
https://www.nxtbook.com/mspc/independentbanker/november2018
https://www.nxtbook.com/mspc/independentbanker/october2018
https://www.nxtbook.com/mspc/independentbanker/september2018
https://www.nxtbook.com/mspc/independentbanker/august2018
https://www.nxtbook.com/mspc/independentbanker/july2018
https://www.nxtbook.com/mspc/independentbanker/june2018
https://www.nxtbook.com/mspc/independentbanker/may2018
https://www.nxtbook.com/mspc/independentbanker/april2018
https://www.nxtbook.com/mspc/independentbanker/march2018
https://www.nxtbook.com/mspc/independentbanker/february2018
https://www.nxtbook.com/mspc/independentbanker/january2018
https://www.nxtbook.com/mspc/independentbanker/december2017
https://www.nxtbook.com/mspc/independentbanker/november2017
https://www.nxtbook.com/mspc/independentbanker/october2017
https://www.nxtbook.com/mspc/independentbanker/september2017
https://www.nxtbook.com/mspc/independentbanker/august2017
https://www.nxtbook.com/mspc/independentbanker/july2017
https://www.nxtbook.com/mspc/independentbanker/june2017
https://www.nxtbook.com/mspc/independentbanker/may2017
https://www.nxtbook.com/mspc/independentbanker/april2017
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