2021, clarifying that SPCPs that conform with the Equal Credit Opportunity Act and Regulation B generally do not violate the Federal Fair Housing Act. The special purpose credit program provisions of ECOA and Regulation B provide a targeted means by which creditors can better serve communities who have been historically shut out or otherwise disadvantaged. While the Fair Housing Act does not speak directly to SPCP, HUD concluded that SPCPs, where instituted in conformity with ECOA and Regulation B, generally would not violate the Fair Housing Act. " The more recent releases from regulatory agencies don't bring significant changes to the table for special purpose credit programs but reemphasize that these tools are available to lenders and how to create a written plan and set up such a program, " observes Marshall. " The issuances encourage lenders to focus the programs on underserved groups who are of certain ethnicities or races. The purpose of the programs is to bring credit at more favorable terms than would be available through the traditional underwriting process. " Community banks should take steps to evaluate whether the current SPCPs they offer are administered consistently with program requirements, including the guidance from HUD regarding the Fair Housing Act and the CFPB guidance about SPCP written plans, and that persons benefiting from the program are eligible. Marshall also suggests banks periodically confirm that there is a continuing need for the program, to demonstrate that there is or is not a need for the program, and to document their evaluation and conclusions. Mary Thorson Wright is a writer in Virginia.