Programs with a Purpose: The Power of Special Purpose Credit

September 17, 2024

On Tuesday, September 17th, more than 50 people gathered at the Boston Foundation for Programs with a Purpose: The Power of SPCPs. Co-hosted by the Wealth Gap Partnership and the Partnership for Financial Equity, this convening brought together financial, legal, and community experts and leaders who spoke about the potential and need for special purpose credit programs (SPCPs) in Greater Boston and throughout Massachusetts.

Lee Pelton, President and CEO of the Boston Foundation, opened the event by expressing the Foundation’s belief in the power of convenings to build collective understanding and commitment and highlighting the powerful role that SPCPs play in narrowing the racial wealth gap.

SPCP wide shot of room

Brook Ames, Chief Legal Counsel at Leader Bank and the Board Chair of the Partnership for Financial Equity, followed Lee’s remarks by uplifting the collective recognition by banking, finance, and community leaders of the wealth and opportunity gaps that exist in our communities – and the role that SPCP programs must play in addressing these discrepancies.

The first panel included Patience Malaba, Executive Director of the Housing Development Consortium of Seattle-King County, and Kenneth Willis, Senior Vice President and Director of Housing and Community Investment at Federal Home Loan Bank of Boston. Shanti Abedin, Vice President of Housing and Community Development at the National Fair Housing Alliance (NFHA), moderated the conversation. Both speakers discussed their experience building and implementing SPCPs that provide down payment assistance to first-time homebuyers of color. They also explained the racial disparities in homeownership in both the State of Washington and the New England region that necessitated the programs.

SPCP panel 1

Patience and Shanti described their roles in passing the Covenant Homeownership Act in Washington state, a groundbreaking piece of legislation that established a statewide SPCP. The Housing Development Consortium helped lead the coalition effort to pass the bill, while NFHA provided critical research support and helped document the history of racially restrictive covenants and other discriminatory housing practices that furthered the racial homeownership gap in Washington.

Ken discussed FHLB Boston’s special purpose credit program, Lift Up Homeownership. While SPCPs can be either people-based, targeting individual borrowers from underserved communities, or place-based, targeting geographic areas, both panelists emphasized that they were intentional in designing people-based programs since they specifically target the individuals harmed by structural racism and have the greatest impact on addressing the racial wealth gap.

The second panel focused on the legal and regulatory hurdles institutions face when establishing and administering SPCPs. Moderated by Brook Ames, with panelists Steve Antonakes, Executive Vice President of Enterprise Risk Management at Eastern Bank, and Zachary Best, Counsel at Relman Colfax, the group discussed how an institution establishes a program and the different standards for various types of organizations. Perhaps unsurprisingly, government-operated programs face the highest standards and must prove that the government was responsible for conducting the harm being addressed and that the proposed solution is narrowly tailored to address said harm. While nonprofit and for-profit organizations are not subject to the same regulations, all institutions must write a plan outlining the demonstrated need for a program as well as the proposed design and implementation. This paperwork and data collection is time-consuming and can be one of the biggest hurdles to establishing an SPCP, Steve said, alongside achieving internal consensus on how the program is structured.

SPCP Panel 2

Both speakers recommended involving regulators when developing the program since they can conduct stress tests and provide feedback before a public launch. Zach also discussed the heightened legal scrutiny that all race-conscious programs face following the Supreme Court’s recent decision to upend affirmative action. He stressed, however, that this is a constitutional issue and private SPCPs are not currently under attack since they are written into the tax code and authorized explicitly under the Equal Credit Opportunity Act.

Following both panels, attendees had the opportunity to connect with selected breakout group leaders. Earlier speakers Ken Willis and Zach Best both hosted a group, along with Abby Nguyen-Burke, Senior Vice President and Team Leader at Eastern Bank, and Alison Tower, Vice President of Compliance and CRA Officer at Hometown Financial Group.

Concluding thoughts and important takeaways, according to the panelists? Have the courage to pursue an SPCP program! Do not be afraid of race-based programs despite legal scrutiny. Expect internal and external pushback, but stay steadfast. The demand and need already exist; it just needs to be fulfilled by these programs.

Agenda

Welcome and Opening Remarks
Brook Ames,Chief Legal Counsel, Leader Bank
Lee PeltonPresident and CEO, The Boston Foundation

Panel Discussion One - "Paving the Way": An Overview of SPCP Programs
Shanti AbedinVice President of Housing and Community Development, National Fair Housing Alliance
Nicole Bascomb-GreenHead of Community Lending, Umpqua Bank
Patience MalabaExecutive Director, Housing Development Consortium

Panel Discussion Two - “Creating a Roadmap”: A Synopsis of Legal and Regulatory Considerations
Brook Ames,Chief Legal Counsel, Leader Bank
Steve AntonakesExecutive Vice President of Enterprise Risk Management, Eastern Bank
Imani CherryAttorney, Relman Colfax

Breakout Group Leaders
Imani Cherry,Attorney, Relman Colfax
Abby Nguyen-Burke,Senior Vice President and Team Leader, Eastern Bank
Alison Tower,Vice President, Compliance & CRA Officer at Hometown Financial Group
Ken Willis,Senior Vice President and Director of Housing & Community Investment, FHL Bank Boston

Closing Remarks
Courtney Brunson, Director, Greater Boston Partnership to Close the Racial Wealth Gap,The Boston Foundation
Thomas CallahanExecutive Director, Partnership for Financial Equity