Q: Are state unemployment payments considered a “public assistance program” for purposes of Regulation B compliance?
A: Yes, state unemployment payments are considered a “public assistance program” for purposes of Regulation B compliance. Regulation B defines “public assistance” as any federal, state, or local governmental assistance program that provides a continuing, periodic income supplement, whether premised on entitlement or need. The term includes (but is not limited to) Temporary Aid to Needy Families, food stamps, rent and mortgage supplement or assistance programs, social security and supplemental security income, and unemployment compensation. 12 CFR § 1002.2(z)(3) (Staff Commentary).
This Q&A was obtained from NCUA’s website, in a document entitled “NCUA Fair Lending Examination and Compliance Program for Federal Credit Unions,” which may be found here: