March 01, 2023

ICYMI: Community Development Advisory Board convenes on CDFI application process, blackout period, more

ColumnThe Community Development Advisory Board Tuesday continued discussions around the new Community Development Financial Institution (CDFI)  Certification Application, which was postponed indefinitely in January. The agency plans on revising the version released for public comment in November. 

During the meeting, CDFI Fund Director Jodie Harris, who last week announced that she will step down from her position at the end of April to serve as President of the Philadelphia Industrial Development, flagged that the fund was changing the certification process as a result of the increase of CDFIs. Harris also noted that the certification policy has not been revised since 1994.

The agency has received over 270 letters in response to its request for comment (RFC) on the CDFI certification application process. Several comments were in response to changes in products and services as well as the removal of the NCUA low-income designation qualifier.

NAFCU highlighted several comments from member credit unions prior to the meeting, raising concerns around needing more transparency and communication from the fund regarding the certification process. The association also shared opposition to the proposed changes to the CDFI certification standards and joined with other trades to raise concerns to lawmakers. NAFCU President and CEO Dan Berger met with Rep. Maxine Waters, D-Calif., earlier this year to highlight that the proposed changes to the application will restrict access to the fund and its resources.

Of note, the CDFI Fund recently issued updates on its Frequently Asked Questions (FAQs) for the CDFI Certification Blackout Period, announcing that organizations seeking certification for the first time prior to the blackout period will now be required to submit a new application within 12 months to demonstrate compliance to the new policies. 

The agency anticipates completing pending certification applications and target market modification application evaluations by the end of April. There may, however, be delays in delivering determinations to some organizations; questions related to the evaluation of a pending application can be submitted through an AMIS Service Request, more information can be found on the CDFI Fund’s website.

NAFCU will continue to heighten CDFI advocacy efforts on behalf of credit unions.