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#2268616 - 04/01/22 10:10 PM Reg B - Special Purpose Credit Program
trying_to_comply Offline
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Joined: Feb 2011
Posts: 126
Can anyone confirm if the USDA Single Family Housing Guaranteed Loan Program is considered a Special Purpose Credit Program?

In determining eligibility for the product, the lender must certify that any household that requests a loan guarantee does not exceed the adjusted annual income threshold for the applicable state and county where the dwelling is located.

In requiring income information from potentially non-applicants/individuals not obligated on the loan, and with that information potentially being alimony, child support, and any separate maintenance income, I feel that it would have to be, but am struggling to confirm that.

Anyone have any experience with the product?

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Fair Lending
#2268622 - 04/02/22 02:15 PM Re: Reg B - Special Purpose Credit Program trying_to_comply
rlcarey Online
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rlcarey
Joined: Jul 2001
Posts: 79,675
Galveston, TX
It is a US Government Guaranteed Program - what is your concern, that you are going to be violating Regulation B by gathering the information required under the program that has been in existence for decades? The answer to your question is yes - it complies with 1002.8(a) - Comment 2.
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The opinions expressed here should not be construed to be those of my employer: PPDocs.com

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#2268636 - 04/04/22 01:53 PM Re: Reg B - Special Purpose Credit Program trying_to_comply
trying_to_comply Offline
100 Club
Joined: Feb 2011
Posts: 126
Thanks Randy - I am aware of the program, but was getting some pushback on whether it was a SPCP and wanted other opinions.

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#2270197 - 05/09/22 05:29 PM Re: Reg B - Special Purpose Credit Program trying_to_comply
MJZMJZ Offline
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Joined: Apr 2020
Posts: 28
If USDA Single Family Housing Guaranteed Loan Program is a SPCP, then do we need do our own Bank's analysis?

From what I read (I may be wrong), for SPCP, we need a written plan, time period of the program will operate or will be revalued and bank’s analysis to determine the need for an SPCP.

Not sure if there is a sample of SPCP or any other resource ?
Appreciate any feedback!

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#2270203 - 05/09/22 06:06 PM Re: Reg B - Special Purpose Credit Program trying_to_comply
rlcarey Online
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rlcarey
Joined: Jul 2001
Posts: 79,675
Galveston, TX
It is not your program. That is all the problem of the USDA.

2. Compliance with a program authorized by Federal or state law. A creditor does not violate Regulation B when it complies in good faith with a regulation promulgated by a government agency implementing a special purpose credit program under §1002.8(a)(1). It is the agency's responsibility to promulgate a regulation that is consistent with Federal and state law.
_________________________
The opinions expressed here should not be construed to be those of my employer: PPDocs.com

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