§§__.11(c)(3) & 195.11(c)(2) – 2
Q: To be a special purpose institution, must an institution limit its activities in its charter?
A2: No. A special purpose institution may, but is not required to, limit the scope of its activities in its charter, articles of association, or other corporate organizational documents. An institution that does not have legal limitations on its activities, but has voluntarily limited its activities, however, would no longer be exempt from Community Reinvestment Act (CRA) requirements if its subsequently engage in activities that involved granting credit to the public in the ordinary course of business. An institution that believes it is exempt from CRA as a special purpose institution should seek confirmation of this status from its supervisory Agency.
Source: Interagency Questions & Answers Regarding Community Reinvestment | July 2016