CFPB Issues Advisory Opinion Addressing Regulatory Uncertainty Regarding Special Purpose Credit Programs
By EsqSocial Corporation 29/12/20
On December 21, 2020, the CFPB issued an advisory opinion that addresses regulatory uncertainty related to certain aspects of special purpose credit programs (“SPCPs”) designed and implemented by for-profit organizations. The advisory opinion was issued as an interpretive rule that will be published in the Federal Register and therefore is exempt from the notice and comment rulemaking requirements of the Administrative Procedure Act....
By: Ballard Spahr LLP