On June 17, 2026, the CFPB rescinded an advisory opinion issued in December 2020 regarding Regulation B as it applies to certain aspects of special purpose credit programs (SPCPs) designed and implemented by for-profit organizations to meet special social needs. Specifically, the advisory opinion clarified the content that a for-profit organization must include in a written plan that establishes and administers an SPCP under Regulation B.

The CFPB finalized a rule in April 2026 that updated several provisions of Regulation B concerning SPCPs. Because the Bureau’s December 2020 advisory opinion includes guidance that now contradicts these regulatory changes, it has been rescinded. For example, while the 2020 opinion suggested that for-profit SPCPs could require participants to share protected characteristics such as race, national origin, or sex, the new 2026 rule prohibits using those specific categories to determine program eligibility. Furthermore, the advisory opinion’s discussion of Regulation B requirements is now considered obsolete or insufficient due to these recent amendments.

This rescission of the advisory opinion aims to avoid any confusion about the appropriate standards and related conditions for SPCPs offered or participated in by for-profit organizations.

The Federal Register Notice can be found here.

Adam Witmer

Adam Witmer is a speaker, author, and founder of the Compliance Cohort. Adam has taught hundreds of seminars and training sessions to thousands of bankers throughout the United States and teaches on all areas of regulatory compliance. Adam has written five e-books that he never published, hit a grizzly bear while driving in a National Park, and is an award winning photographer and musician (though he no longer takes photos nor plays any instruments). In his spare time, Adam can be found kayaking on the lake, doing taekwondo with his kids, working on his (project) house, or spending time with his family.

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