CFPB Rescinds 2020 Advisory Opinion on SPCPs

Adam Witmer
Regulation B, Regulatory Update

On June 17, 2026, the CFPB rescinded an advisory opinion issued in December 2020 regarding Regulation B as it applies to certain aspects of special purpose credit programs (SPCPs) designed and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. 

Trump Nominates New CFPB Leader

Adam Witmer
Regulatory Update

On June 10, 2026, the ABA Banking Journal reported that President Trump nominated Brian Johnson to serve as the next director of the Consumer Financial Protection Bureau (CFPB) for a five-year term. Johnson currently serves as an executive at Capital One and previously held a leadership role at the CFPB during Trump's first administration.

CFPB Releases Statement on Ability To Repay and Immigration Status

Adam Witmer
Regulatory Update, Regulation Z

On June 8, 2026, the CFPB issued a statement to remind creditors of their obligations under the Truth in Lending Act (TILA) and consistent with President Trump's E.O. “Restoring Integrity to America's Financial System.” TILA and its implementing Regulation Z require creditors to assess consumers' ability to repay before offering mortgages and certain open-end credit products.

New York DFS Reminds Lenders of Fair Lending Obligations

Adam Witmer
Fair Lending, Regulatory Update

On April 22, 2026, the New York State Department of Financial Services (DFS) issued an industry letter reminding entities regulated under the New York Banking Law of their obligations under New York Executive Law Section 296-a, the state's fair lending law. DFS emphasized that it has the authority to enforce state fair lending laws and to impose penalties for violations of federal fair lending requirements.

CFPB Faces Lawsuit Over Changes to Fair Lending Enforcement

Adam Witmer
Regulatory Update, Fair Lending

On May 28, 2026, the ABA Banking Journal reported that a coalition of consumer groups and fair lending compliance firms has filed a lawsuit to prevent the CFPB from removing disparate impact as a prohibited practice from Regulation B, which implements the Equal Credit Opportunity Act (ECOA). The federal agencies recently removed disparate impact liability from their supervision and enforcement activities following an April 2025 executive order directing agencies to eliminate its use in all regulatory and enforcement contexts.

OFAC Updates SDN List

Adam Witmer
BSA, Regulatory Update

On May 28, 2026, the OFAC updated its Specially Designated Nationals and Blocked Persons (SDN) List by removing sanctions on 76 outdated targets. According to its press release, the removals are part of Treasury’s ongoing sanctions modernization initiative.

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